Do the purchase price allocation rules alter the tax book values of Farmland Improvements and listed horticultural plants under subpart DO?
Under subpart DO, a purchaser of farmland with Farmland Improvements and listed horticultural plants who carries on a farming business on the land is allowed an annual amortisation-like deduction of the diminished values of the improvements and plants. The opening tax book values for the purchaser is the seller‘s tax book values for the improvements and plants at the beginning of the income year of the sale. This question we’ve been asked considers whether the purchase price allocation rules alter this treatment. It concludes that they do not.
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