08-10-1982 Industrial Development Corporation Board of Directors Meeting

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:.~ ,~ +~ i 18. Cost of mobile buildings for use as temporary offices even though the mobile buildings later are sold to un- - - related parties. Rev. Rul. 75-208, 1975-1 C.B. 46~. 19. Research and experimental. expenditures (including com- puter software,.Rev. Proc. 69-21, 1969-2 C.B. 303) allo- cable to facilities where mar_•.:fact•.:ring will occur even though deducted as expenses. Rev. Rul. 77-27, 1977-1 C.B. 23; LTR 8052071. See Rev. R•sl. 77-253, 1977-2 C.B. 40~._ See also IrTR 8042136 (definition of research and experimental expenditures). 20. Circulation expenditures even though deductible under Section 173 of the Code. 21. Intangible drilling costs even though deductible under Section 263(c) of the Code. 22. Cost~of property obtained under a lease which is treated as a sale for federal income tax-purposes. Treas. Reg. - §1.103-10(b)(iii); Treas. Reg. §2.103-10(f) Example 13. - -~ 23`. Assumption of liabilities in cor~necti on with the pur- chase of property. See Crane'v:- Commissioner, 331 U.S. 1 (1947). - 24. Organizatior_ expenditures of a -corporation or a p~rt_ nership, even though amortized under Sections 248 or 709, respectively, of the Code. But see LTR 8014111 (organization expenditures not papa or incurred with respect to facilities in the city in which the financed facility is located and, therefore, not Section 103(b) (6)(D) capital expenditures). 25. Interest prepayments of a cash (or accrual) basis tax- payer. See IRC §461(g). 26. In the case of an individual (including a partner), a subchapter S corporation or a personal holding company, real property and construction period interest and taxes required to be capitalized under Section 189 of the Code. 27. Cost of real property including water rights, ease- ments (see Rev. Rul. 80-100, 1980-1 C.B. 25} and the net cost of demolition of an existing building (LTR 8024079). -