...respect to the real estate owned by the company. No deduction shall be allowed under this paragraph for any amount paid out for new buildings, or for permanent Improvements or betterments made to Increase the value of any property. (3) Depreciation. The deduction allowed by section 167. The deduction under...

...disallowance of deductions. SEC. 261. General rule for disallowance of deductions. In computing taxable income no deduction shall in any case be allowed in respect of the items specified in this part. § 1.261-1 General rule for disallowance of deductions. In computing...

...the exceptions provided in part IX . . . .- IRC 1 1*1. " "No deduction shall be allowed for— (1) Any amount paid out for new buildings or for permanent...to increase the value of any property or estate." IRC |263(a)(l). " Commisiumrr o. IAJu Powrr Co., 74-2 usic 19521. 41» US 1, 17. •See Id.; but see...

...this subsection. (26 USC (1952 ed.), Sec. 23.) Sec. %4- Items Not Deductible — (a) General Rule. — In computing net income no deduction shall in any...made to increase the value of any property or estate; * * * ***** (26 USC (1952 ed.), Sec. 24.) The husband may not, under section 23 (u), deduct from his...

...Appeals CENTAUR database. Section 263: Capital Expenditures The IRC does not allow the deduction of any amount paid out for new buildings or for permanent...made to increase the value of any property or estate. This does not apply to several expenditures that are allowed under sections 174, 176, 179, 180, 190,...

...requires capitalization of expenditures which provide enduring benefits to the taxpayer, including "any amount paid out for new buildings or for permanent...to increase the value of any property or estate." IRC § 263(a)(l). The primary definitional ambiguity in applying these general statutory and regulatory...

...treatment of G&G costs. In general, under the Code, no current deduction is allowed for any amount paid for new buildings or for permanent improvements or...made to increase the value of any property or estate (sec. 263(a)). The regulations define capital amounts to include amounts paid or incurred (1) to add...

...under a confusingly worded provision entitled "Capital expenditures," denies a current deduction for "(a]ny amount paid out for new buildings or for permanent...betterments made to increase the value of any property or estate."36 A regulation further states that this means physical property with a life of "substantially"...

...Geophysical Costs Present Law Under present law, current deductions are not allowed for any amount paid for new buildings or for permanent improvements or...betterments made to increase the value of any property or estate.800 Treasury Department regulations define capital amounts to include amounts paid or incurred...

...(1933). ERC SECTION 263 IRC section 263 of the Code allows no deduction for a capital expenditure -- an "amount paid out for new buildings or for permanent...to increase the value of any property or estate." @ 263(aXl). The primary effect of characterizing a payment as either a business expense or a capital...