A hazardous ruling: the Service denies deductibility of asbestos mitigation costs
Article Abstract:
IRS Technical Advice Memorandum (TAM) 9240004 on tax deductions for toxic cleanup and asbestos mitigation costs did not give clear guidance and in fact misapplied the case law in this area. The IRS ruled that toxic mitigation efforts to be a production activity requiring capitalization of costs under IRC 263A. In today's bad economy, industry ability to foot cleanup expenses may hinge on their deductibility, which public policy would also seem to favor. Congress should compromise by adding a short amortization period.
Publication Name: Journal of Real Estate Taxation
Subject: Real estate industry
ISSN: 0093-5107
Year: 1993
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Economic performance: the deductibility of estimated future costs of real estate development
Article Abstract:
Revenue procedure 92-29 is helpful for real estate developers who wish to deduct estimates of future improvement costs from their basis when they sell property. For example, the statute of limitations waiver applies only to computation aspects of the procedure. Allocation methods include choices of equal basis, consent or a ten year horizon. Other less helpful methods remain with revenue procedure 75-25 or IRC section 461(h).
Publication Name: Journal of Real Estate Taxation
Subject: Real estate industry
ISSN: 0093-5107
Year: 1993
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Deductibility of environmental cleanup costs: the debate continues
Article Abstract:
The IRS has issued technical advice memorandum 9315004 covering the capitalization and tax deduction of cleanup costs for environmental pollution. Costs must be assigned to related assets instead of deducted currently. This memorandum applies to contamination of a site by PCB chemicals, while an earlier ruling covered asbestos pollution. These two rulings provide initial guidelines which will be elaborated.
Publication Name: Journal of Real Estate Taxation
Subject: Real estate industry
ISSN: 0093-5107
Year: 1993
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- Abstracts: Purchase-money mortgages: the Service clarifies the deductibility and reporting of points. Expenses related to tax-exempt income: interest and property tax deductions disallowed for civilian government employees receiving living quarters allowance
- Abstracts: Reducing the cyclical volatility of real estate development. Riskless benefits from longer lease terms
- Abstracts: 1988 Fair Housing amendments force expensive retrofitting of multi-unit developments. The future of mediation and arbitration in the real estate industry
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- Abstracts: Busy signal: the explosive growth of call centers. Mining booms in Ontario's North. Dial-up Ontario