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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.

§ 1.167(a)-8(a), which permits, in part, a loss from physical abandonment of retired property. Under §§ 263(a) and 1.263(a)-1(a), no deduction is allowed for capital expenditures, such as amounts paid for new buildings or for permanent improvements or betterments made to increase the value of any property. Section 1.263(a)-2(a)

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