How the IRS Examines Repair and Maintenance Costs

Taxpayers are generally allowed to deduct the cost of making incidental repairs to their property used in carrying on any trade or business under IRC § 162 and Treas. Reg. § 1.162-4. However, to be deductible currently, a repair cost must not be subject to capitalization under IRC § 263(a). Specifically, no deduction is allowed for (1) any amount paid for new buildings or for permanent improvements that increase the value of the property or (2) any amount spent restoring property or in making good the exhaustion of property for which a depreciation allowance has been made. Treas. Reg. § 1.263(a)-1(b) specifies that capital expenditures include amounts paid or incurred to (1) add to the value or substantially prolong the useful life of property owned by the taxpayer or (2) adapt the property to a new or different use.