For income-producing properties, the income capitalization
approach tends to be a more thorough and accurate determination of market value and, in fact, well-suited for capturing changes in revenues and expenses resulting from a facade preservation easement donation.
Subsequently, several circuit court decisions interpreted that case to mean that the Supreme Court had adopted a new test for determining whether an expenditure was deductible currently or required capitalization
Whether in response to the emergence of a new generation of intangibles that did not fit neatly within the decades old template of capitalization
principles, its string of losses before appellate courts permitting deductions for an array of costs, (10) or the continuing perception of revenue agents gone wild, the National Office and Treasury committed to issue regulations fundamentally changing the capitalization
We urge the government likewise to consider the proposal seriously as it moves forward to effect the capitalization
guidance announced on the 2001 Priority Guidance Plan.
According to NAREIT, increased REIT market capitalization
has enhanced overall liquidity, which, in turn, has greatly increased the attractiveness to institutional investors over the last several years.
The TAM does not address the proper treatment of expenses incurred to develop an alternative cleanup plan; however, if such expenses are part of the plan (because XYZ or some other taxpayer might incur them to determine the best method of cleaning up the contamination), the IRS generally requires capitalization
This category includes seven specific types of costs that will likely require capitalization
Finally, during the liaison meeting, Treasury Department representatives indicated that the government is considering other issues on which to issue broad-based capitalization
guidance, including the plan-of-rehabilitation doctrine and the definition of repairs.
Under the 1988 IRS notice, it was clear that interest capitalization
was required during construction of buildings and personal property with a class life of 20 years or more.
The Service noted, however, that the bank's characterization of some of the acquisition costs as investigatory raised questions about whether capitalization
of those costs was consistent with Rev.
Indeed, despite frequent public assurances from the IRS National Office that "INDOPCO did not change the law regarding capitalization
,"(2) agents have seized upon that decision's reference to "future benefits" to support novel capitalization
The IRS had previously conceded that the legal expenses attributable to the investigatory stage of the transaction should have been allowed as a deduction, and that the Tax Court was wrong in requiring capitalization
of all of DBTC's legal fees.