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CAPITAL AND REVENUE EXPENDITURES FOR FEDERAL TAX INCOME PURPOSES.

The Accounting Review 1951 26(3), 387-394
In conclusion, the following general principles may be drawn from the study of cases and rulings surveyed in this paper: 1. Costs of acquiring property, including payments of liabilities assumed upon acquisition, constitute capital expenditures. 2. Repairs should be capitalized if they increase the value of an asset, prolong its life, or make it adaptable to a different use. Otherwise, they represent proper deductions from gross income. 3. Expenditures made to protect the taxpayer's business or property are generally held to be deductible provided they do not result in the acquisition of an asset of a capital nature. However, the Commissioner usually contends that such expenditures are nondeductible either because they are not "ordinary" or because they represent payments for goodwill. 4. Lump sum investments in leaseholds may be amortized over the life of the lease. Leasehold improvements, on the other hand, are recoverable over the life of the improvement or the term of the lease, whichever is shorter. 5. In the earlier decisions regarding the deductibility of the cost of demolition as a loss, the intention of the taxpayer at the date of acquisition of the property was the determining factor. However, more recent decisions have shown that capitalization is in order where the demolition is merely one step in an uncompleted transaction which calls for the substitution of a more valuable asset for one of lesser value.