02-13-1984 Industrial Development Corporation Board of Directors Meeting (2)

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• •~ i i i i a l during the te:~porary period). See also Treas. Reg. §1.256-i(b)(1)(iv) (taxpayer permitted to capitalize - "any ot~-~er taxes and carrying charges with respect -to - property, whic:Z in .the opinion of the Commissioner, are, u deg scund accounting principles, chargeable to CaDitx~ aCCOUnt"). 3. Issux_nce costs (underwriting fees, legal fees, printing • costs, ~ etc. ); but, of course, only if paid. other than out of -the bond proceeds. Rev. Rul. 77-23x, 1977-2 C.B. 39. a. P.mou^ts extended for securing a copyright and plates that remain the property of the person making the pay- ments. See Treas. Reg. §1.263(x)-2-(b). 5. Cost of defending or-perfecting title to property. See Treas. Re;. §1-263(x)-2(c). 6. F.~~cunts expended .for architect's services. See Treas. . Reg. §1.263(a}-2(d). ~~ 7.~ A corporation's cash acquisition of stock of another coracrati on followed by a licruia.ation of the acquired _ co~ora~ion to which Section 334(b)(2) of the Code ap- plies is in substance an .acquisition of underlying as- sets, and, therefore is a capi~i expenditure with re- . spect to the acquired corporation's facilities to the exter_t of the percentage of the corporation's fixed assets located in the county (or incorporated munici- pality). The capital expenditure, however, is reduced by t~.e amount expended by the acquired corporation from proceeds of an outstanding prior small issue for depre- ciable tangible assets located in the county (or incor- porated municipality). LTR 7916021. 8. Co~-nmissions paid in purchasing stock as described in "6." abov_. S=-° '"rea_=. Reg. §1.263(x)-2(e). 9. 10. Cost of goodwill or a covenant not to compete in con- nection with the acquisition of the assets of a going concern. Rev, Rul. 81-56, 1981-8 I.R.B. 7'; Rev. Rul. 81-55, 1981-8 I.R.B. 6. See Treas. Reg. §1.263(x)-2(h). TraCema_k xnd tradena.*~e •expenditures even ~~.hough amor- tizable under Section 177 of the Code.