[IMGCAP(1)]The IRS recently made it clear that even if taxpayers engage a third party to perform a cost segregation analysis, they cannot avoid penalties for aggressive positions taken in the cost segregation report.
The recently released Chief Counsel Memo #20125201F involved the issue of improperly classifying a parking deck as a 15-year land improvement instead of a 39-year building. A taxpayer had attended a presentation that addressed open-air parking structures in which the presentation slides indicated certain regulations “support the argument that parking structures belong in the land improvement category.”
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