Application
The cost of the transportation equipment used for construction activities was paid out in the same manner as the cost of supplies, materials, and the wages of construction workers. The taxpayer does not question the capitalization of these other items, because they are elements of the cost of acquiring a capital asset. Thus, construction-related depreciation should also be capitalized.
§161 and §261 of the Internal Revenue Code require that the capitalization provision of §263(a) take precedence, on the facts here, over §167(a)
Read more about this topic: Commissioner V. Idaho Power Co.
Famous quotes containing the word application:
“The application requisite to the duties of the office I hold [governor of Virginia] is so excessive, and the execution of them after all so imperfect, that I have determined to retire from it at the close of the present campaign.”
—Thomas Jefferson (1743–1826)
“The receipt to make a speaker, and an applauded one too, is short and easy.—Take of common sense quantum sufficit, add a little application to the rules and orders of the House, throw obvious thoughts in a new light, and make up the whole with a large quantity of purity, correctness, and elegancy of style.”
—Philip Dormer Stanhope, 4th Earl Chesterfield (1694–1773)
“I think that a young state, like a young virgin, should modestly stay at home, and wait the application of suitors for an alliance with her; and not run about offering her amity to all the world; and hazarding their refusal.... Our virgin is a jolly one; and tho at present not very rich, will in time be a great fortune, and where she has a favorable predisposition, it seems to me well worth cultivating.”
—Benjamin Franklin (1706–1790)