...DEDUCTIONS NOT ALLOWED.—In computing net income, no deductions shall be allowed in any case for—- (2) Any amount paid out for new buildings or for permanent improvements or betterments, made to increase the value of any property or estate; (1) Personal, living, or family expenses; (3) Any amount expended...

...on any trade or business".8 Section 263(a)(l) generally provides that a deduction is not allowed for "Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate." Whether an expense is deductible under section 162(a) or must...

...expenditures are within the purview of section 263, which provides that no deduction shall be allowed for any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of the property. Where a casualty loss is allowed for the loss of property, the amount of...

...a failure at that time. Section 263 (a) of the Code provides that no deduction shall be allowed for any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate. Section 162 (a) of the Code provides, in part, that there shall...

...Internal Revenue Code of 1954 provides, in part, that no deduction shall be allowed for any amounts paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate. Section 1.263 (a) -2 of the Income Tax Regulations provides, in...

...computing net Income no deduction shall In any case be allowed In respect of • •••••• (2) Any amount paid out for new buildings or for permanent Improvements or betterments made'to Increase the value of any property or estate, except expenditure* for the development of mines...

...of the issue before us. By •equiring the capitalization of amounts "paid out for new buildings >r for permanent improvements or betterments made to increase the ?alue of any property," such section begs the very question we are asked 0 answer. We are satisfied that, under the circumstances...

...provision must be read in the light of § 263(a)(l) which specifically disallows any deduction for an amount "paid out for new buildings or for permanent improvements or betterments." He argues that § 263 takes precedence over § 167 by virtue of what he calls the "priority-ordering"...

...CAPITAL EXPENDITURES (a) GENERAL RULE. — No deduction shall be allowed for — (1) Any amount paid oat for new buildings or for permanent Improvements or betterments made to Increase the value of any property or estate. This paragraph shall not apply to — • ••*»* • Petitioner's...

...* 6 Sec. 263(aXl) provides: SEC. 263(a). GENERAL RULE.— No deduction shall be allowed for— (1) Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate. * * * the expenditure is incurred is undeniably important in determining...