On March 16, 2012 the Internal Revenue Service (IRS) issued a Large Business & Industry (LB&I) Directive for taxpayers directly relating to the temporary regulations "Repair Regulations". The IRS states that “This directive applies to the exam activity relating to positions taken on original returns relating to the following issues.”
1. Whether costs incurred to maintain, replace, or improve tangible property must be capitalized under section 263(a), (see, e.g., Rev. Proc. 2011-14, Appendix section 3.06, Repair and maintenance costs (designated change number 144)); and,
2. Any correlative Issues involving the disposition of structural components of a building or dispositions of tangible depreciable assets (other than a building or its structural components), (see, e.g., Rev. Proc. 2011-14, Appendix sections 6.24 and 6.25 (designated change number 146 and 147, respectively)).
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