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r. <br />• • <br />28. Expenditures by a ground lessor on the leased ground <br />are capital expenditures with respect to a bond-financed <br />facility on the leased ground; but only if the expendi- <br />tures are made within three years before or after the <br />date of the bond issue. LTR 783301-_; LTR 7951067; LTR <br />8011062; LTR 8149042; LTR 81^9049. Furthermore, <br />expenditures by tenants of a mall for leasehold improve- <br />ments that are fixtures under local law are capital <br />expenditures with respect to the mall building; but <br />only if made within three years before or after the <br />date of the bond issue. LTR 8149049; LTR 8313074. <br />Conga LTR 8037075. See also LTR 819042 (not capital <br />expenditures if tenant improvements will be worth less <br />than 10% of thei r cost when they revert to the land- <br />lord). However, expenditures by ter.arts of a mall for <br />personal property under local law are not capital <br />expenditures with respect to t'~e mall build; ng. LTR <br />8037075; LTR 8149049; LTR 8317083. - <br />29. Cost of option with term of more than one year. LTR <br />8218057. See Zaninovich v. Comm;ssioner, 61o F.2d 429 <br />(9th Cir. 1980). <br />30. Certain real property construction period interest and <br />taxes required to be capitalized under Section i89 of <br />the Code. <br />31. Research and experimental expenditures (including <br />computer software, Rev. Proc. 69-21, 1969-2 C.B. 303) <br />allocable to facilities where manufacturing will occur <br />even though deducted as expenses. Rev. Rul. 77-27; <br />1977-1 C.B. 23; LTR 8052071. See Rev. Rul. 77-253, <br />1977-2 C.B. 40. See also LTR 8042135 (definition of <br />research and experimental expenditures).r_owever, <br />certain in-house research expenditures (if creditable <br />under Section 44F and deducted under Section 174(a)) <br />made after September 3, 1982, are not capital expendi- <br />tures. IRC § 103(b)(6)(F)(iv). <br />32. Certain expenditures to establish, maintain or increase <br />the circulation of a newspaper, magazine or other <br />periodical even though d-educt_ble under Section 173 of <br />the Code. <br />33. Trademark and tradename extendi-u_es even though <br />amortizable under Section 177 0_° ~ e Code. <br />-6- <br />