The history of Cost Segregation goes back many years beginning in 1959. Throughout the years there have been many permutations of Cost Segregations but none more significant than the present methodology.
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1959 |
Shainberg vs. Commissioner |
Established the validity of segregation costs for income tax depreciation purposes
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1973 |
Revenue Ruling 73-410 |
Allows that taxpayers may separately depreciate elements of used property where a qualified appraiser allocates the costs between depreciable building components and non-depreciable land as of the date of purchase.
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1975 |
Whiteco Industries, Inc. vs. Commissioner |
Established a six element test to determine if a particular asset qualifies as personal property.
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1987 |
Revenue Procedure 87-56 |
This Revenue Procedure establishes class lives and recovery periods for different assets providing the incentive to re-classify assets into shorter depreciable periods.
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1999 |
HCA vs. Commissioner |
The courts determined and the IRS acquiesced in the principle that :the tests developed under the investment tax credit (ITC) prior to the 1981 adaptation of the cost recovery system are applicable in determining a structural component for purposes of the Accelerated Cost Recovery System (ACRS) and Modified Accelerated Cost Recovery System (MACRS).”
This is the watershed case that underlies modern cost segregation studies.
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2004 |
Audit Techniques Guideline Issued |
Provides guidelines to IRS field agents as to the elements of a quality Cost Segregation Study. |