University National Bank v. Commissioner

Board of Tax Appeals

University National Bank v. Commissioner

21 B.T.A. 71

CourtUnited States Board of Tax Appeals

DecidedOctober 16, 1930

DocketDocket No. 34642

StatusPublished

Cited by2 cases

This text of 21 B.T.A. 71 (University National Bank v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

University National Bank v. Commissioner, 21 B.T.A. 71 (bta 1930).

Pincite

Opinion

[73]*73OPINION.

Arundell:

Petitioner has expended approximately $20,000 for enlarging its banking facilities. In order to accomplish its plan of improvement it found it necessary to tear out a staircase, remove two partitions, provide temporary lighting and plumbing facilities, etc., as set forth in our findings of fact. The .cost of this portion of the work it seeks to take as a deduction. It makes no claim based on a loss of useful value by reason of this work.

It seems to us that the removal of the walls, staircase, etc., was but an incident to enlarging the bank’s floor space, and increasing its facilities and it can not be separated therefrom. It was all part of one plan and one improvement and as it was distinctly a betterment and not an expense, the entire cost must be capitalized. Cf. Federal-American National Bank, 9 B. T. A. 1043.

Decision will be entered, for the respondent.

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