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a • • <br />~ '1. ~~, <br />r <br />services; (ii) such property, though installed in or <br />connected to the facility, is not an integral part of <br />the facility such that the cost of such property is <br />ordinarily included as part of the acquisition, con- <br />struction, or reconstruction cost of such facility; and <br />(iii) such property is of a type normally paid for in <br />the form of periodic fees based upon time or use. <br />Treas. Reg. § 1.103-10(b)(2)(iv)(a); LTR 8313074. <br />20. Cost of moving already owned equipment or machinery <br />(including removal costs) except for taxes and carrying <br />charges which may be capitalized under Section 266 of <br />the Code. See Rev. Rul. 70-392, 1970-2 C.B. 33; <br />Eastern Shoe Marufacturin Co., 8 B.T.A. 1159 (1927), <br />acc. , VZ I-1 C.B. 9; Addressogratih-Multicraoin Corn. , 4 <br />T.C.M. 147 (1945); Fowler & Union Horse Nail Co. Irc., <br />16 B.T.A. 1071 (1929). But see Clarence E. 3aldwin, 1-_ <br />T.C.M. 794 (1955); Winnett v. Helvering, 68 F.2d 6i4 <br />(9th Cir. 1934}; Darlington Veneer Co., Znc., B.T.A. <br />Memo. Cf. Rev. Rul. 79-135, 1979-1 C.3. 78 (Section 103 <br />"substantially a11" test - installation cost of mewed <br />equipment is depreciable property); Rev. Rul. 80-3~6, <br />1980-2 C.B. 47 (Section 103 "substantially all" test - <br />moving cost of property purchased from unrelated <br />corporation is depreciable property). <br />21. Theoretical interest of a taxpayer using his owr_funds. <br />See Treas . Reg. § 1.266-1(b) (1) (iv) . <br />22. Certain in-house research expenditures (if creditable <br />under Section 44F and deducted under Section 174(a)) <br />made after September 3, 1982. IRC g 103(b)(6)(F)(iv). <br />23. Research, development and testing services performed <br />for unrelated party if no patentable or licensable <br />interests in the technology developed are retained. <br />LTR 8304115. <br />24. Expenditures required by circumstances which could not <br />be reasonably foreseen on the date of issue or arising <br />out of a mistake or fact (but the aggregate amount of <br />such exile..^.ditures with respect to any issue stall not <br />exceed $1,000,000). IRC § 103(b)(6)(F)(iii). <br />25. Expenditures re~.:ired by a change made after the date <br />of issue of the issue in cuestion in a Federal or State <br />law or 'ecal o_di:-:ance of genera'_ application. (or rule <br />_ii <br />