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1~ a>, • <br />.~ <br />34. Cost of certain depreciable business property even <br />though deductible under Section 179 of the Code. <br />35. Expenditures by farmers for fertilizer, lime, etc. even <br />though deductible under Sectior_ 180 of the Code . <br />36. Expenditures by~ farmers for clearing land even though <br />deductible under Section 182 of the Code. <br />37. Cost of railroad rolling stock even though amortizable <br />under Section 184 of the Code. <br />38. Intangible drilling costs even though deductible under <br />Section 253(c) of the Code. <br />39. Mining development expenditures even t:7oug deductible <br />under Section .616 of the Code . <br />40. Mining exploration expenditures even though deductible <br />under Section 617 of the Code. <br />" 41. Expenditures paid or incurred with respect to a <br />facility that are not otherwise taken into account in <br />the accruisition cost or as an outstanding prior exempt <br />small issue. Rev. Rul. 76-427, 1976-2 C.3. 28. 3ut <br />see LTR 8017077 (expenditures by unrelated party prior <br />to offer for aco1-uisiti on of lot not ca_oital <br />expenditures); LTR 8239051 (expenditures by former <br />principal user of purchased facilities not capital <br />expenditures); LTR 8304115 (expenditures by purchasing <br />lessee for leasehold improvements not capital. <br />expenditures to extent that fair market value of <br />leasehold improvements reflected in purchase price). <br />The following are examples of expenditures which should <br />not be "capital expenditures": <br />1. Administrative costs, overhead, and wages (unless <br />allocable to the accruisition, construction, or erection <br />of property described in "1." above). <br />2. Cost of incidential repairs or nainterarce. See :teas. <br />Reg. § 1.263(a)-1(b). <br />3 . Cost of property which would properly be i :eluded i n <br />inventory i f on nand at the end o~ t ta:~able near <br />-7- <br />