The IRS disallowed the deduction and capitalized
the bargain element of the warrants based, in part, on the theory that the differential constituted an expenditure to create a long-term relationship.
If this threshold is exceeded, all costs must be capitalized
The entire purchase price had to be capitalized
67-125, the portion of compensation paid to employees in connection with services relating to a reorganization must be capitalized
Inherently facilitative" costs: Costs listed as "inherently facilitative" are not subject to this exception and must be capitalized
, no matter when incurred.
In reciting the facts of the case, the Tax Court noted that the company accounted for the acquisition as a purchase, not a pooling, and capitalized
the expenditures for book purposes.
Therefore, the recurring or nonrecurring nature of an expenditure serves as a practical guideline to determine whether an expenditure is to be deducted or capitalized
Payments for the development of computer software (although this may be capitalized
under other published guidance); and
Therefore, the court treated the payment as a modification fee to be capitalized
and amortized over the life of the new lease.
92-80 (advertising capitalized
if "directed towards obtaining future benefits") and Rev.