Transcription of Part I Section 263.–Capital Expenditures
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Part I Section 263.–Capital Expenditures
part ISection 263. capital Expenditures26 CFR (a)-1: capital Expenditures ; in general.(Also 162, 165, 167, 263A; , (a)-8, (a)-11, )Rev. Rul. 2000-7 ISSUEIf the retirement and removal of a depreciable asset occurs in connection withthe installation or production of a replacement asset, are the costs incurred in removingthe retired asset required to be capitalized under 263(a) or 263A as part of the cost ofthe replacement asset?FACTSThe assets of X, a telephone company, include telephone poles A and B. Xplaced Pole A in service in 1979 on land it owned. X placed Pole B in service in 1982on land owned by Y under the terms of an easement permitting X to have one pole onY's land. In 2000, X undertakes a project to replace telephone poles in the servicearea in which Pole A is situated. As part of that project, X incurs costs in 2000 inremoving and discarding Pole A and installing a new telephone pole, Pole C, in thesame location. X also undertakes a second project to replace telephone poles in theservice area in which Pole B is situated.
-2-LAW AND ANALYSIS Section 162 of the Internal Revenue Code and § 1.162-1 of the Income Tax Regulations generally allow a deduction for all …
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