...the mine, or (2) Do not decrease the cost of production of mineral units, or (3) Do not represent an amount expended in restoring property or in making...thereof for which an allowance is or has been made shall be deducted as ordinary and necessary business expenses. (b) Special nue. For special provisions...

...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...

...Section 263 of the Code provides, in pertinent part, that no deduction from income is allowable for any amount expended in restoring property or in making...thereof for which an allowance is or has been made. Section l.611-3(a) of the Income Tax Regulations provides, in pertinent part, that amounts paid or...

...deduction shall in any case be allowed in respect of — (1) Personal, living, or family expenses; * * * (2) Any amount paid out for new buildings or for permanent...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"...

...recovered over an appropriate period. Section 263 defines a capital expenditure as any amount paid for new buildings or for permanent improvements or...made to increase the value of any property or estate. A capital expenditure also includes any amount expended for restoring property or in making good the...

...(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...