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<br />., <br />building•situated thereon (LTR 802-_079; see Treas. Reg. <br />§ 1.165-3) and the amount expended for demolition of a <br />certified historic structure, whether or not the irtert <br />to demolish existed at the time of tre purchase cf the <br />real property (see IRC § 2808) . <br />'3. Interest on a construction loan, interest or. a loan to <br />purchase real property, interest on a loan to purchase, <br />transport, or install personal property, and interest <br />on a mortgage of unimproved and unproductive real <br />property and other items (including certain taxes and <br />insurance payments) to the extent permitted to be <br />capitalized under. Section 266 of the Cede and the <br />regulations thereunder, even though deducted as <br />expenses. Rev. Rul. 75-185, 1975-1 C.B. 43; Rev. Rul. <br />77-262, 1977-2 C.3. 41 (full amount of interest paid on <br />the bond is a capital expenditure not o_'rset by income <br />from investing proceeds during the temporary period); <br />Rev. Rul. 82-117, 1982-24 I.R.3. 4. LTR 8208108 <br />(interest paid by savings and loan. association or. <br />deposits not interest on a construction loan for the <br />savings and 1•o an association which may be capitalized <br />under Section 266 and, thus, not a capital <br />expenditure); LTR 8318049 (interest, taxes, etc. <br />allocated between portion of tract already developed <br />and portion undergoing development). See Rev. Rul. <br />81-23, 1981-4 I.R.B. 8 (interest or. the bonds between <br />the issuance date of the bonds and the date of <br />commencement of construction of a factory or the <br />purchase of equipment may be capitalized under Section <br />266). See also Treas. Reg. § 1.266-1(b) (1)(iv) <br />(taxpayer permitted to capitalize "any other taxes and <br />carrying charges with respect to property, which in the <br />opinion of the Commissioner, are, .under sound <br />accounting principles, chargeable to capital account"). <br />4. Real property construction period, interest and taxes <br />required to be capitalized under Section 189 of the <br />Code. <br />5. Issuance costs including underwri ring fees, legal fees <br />and printing costs. Rev. Rul. 77-234, 1977-2 C.B. 39. <br />6. Cost of defending or per`ectirg t~tle to prooerty. See <br />Treas. Reg. § 1-253(a)-2(c). <br />-2- <br />