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

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~ ~ l8. 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. a6. 19. Research and experimental expenditures (including com- puter software,.Rev. Proc. 69-21, 1969-2 C.B. 303) allo- cable to facilities where mer_~~fact•~r= ng will occur even though deducted as expenses. Rev. Rul. 77-27, 1977-1 C.3. 23; LTR 8052071. See Rev. R•11. 77-253, 1977-2 C.B. ~0. See also LTR 802136 (definition of research and experimental expenditures). 20. Circulation expenditures even though deductible under Section 173 of the Code. 2l . Ir_tangi ble dri lli ng comets even though dedi:cti ble 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-uurooses. Treas. Rec. - § 1.103=10 (b) (iii) ; Treas . Reg. §1..103-10 (f ) Exa.*~ple 13 . - -~ 4 23~. Assu.~notion of liabilities in connection with the pur- chase of property. See Crane v~:- Com_missi over, 331 U.S. 1 (197). 2~. Organizatior_ expenditures of a corporation or a pzrt- nership, even though amortized under Sections 2~8 or 709, respectively, of the Code. But see LTR~801a111 (organization expenditures not pa a or r_curred 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 t_~,e 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 802079). -