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 best political economy is the care and culture of men; for, in these crises, all are ruined except such as are proper individuals, capable of thought, and of new choice and the application of their talent to new labor.”
—Ralph Waldo Emerson (1803–1882)
“It is known that Whistler when asked how long it took him to paint one of his “nocturnes” answered: “All of my life.” With the same rigor he could have said that all of the centuries that preceded the moment when he painted were necessary. From that correct application of the law of causality it follows that the slightest event presupposes the inconceivable universe and, conversely, that the universe needs even the slightest of events.”
—Jorge Luis Borges (1899–1986)
“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)