Ezel / IRS Rulings / 200922033

CCA 200922033: Email identified the regulation defining self-constructed property

Number
200922033
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Additional First Year Depreciation
Topics
Income and deductions
Code sections
§ 168
Ruling dated
April 9, 2009
Publicly released
May 29, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel responded to a question about regulations under section 168(k), concerning additional first-year depreciation. The email directed the reader to Treasury Regulation section 1.168(k)-1(b)(4)(iii)(A) for the definition of self-constructed property. It supplied that reference without describing any property or deciding whether a particular asset met the definition.

Ruling snapshot

  • Question: Where was self-constructed property defined in the section 168(k) regulations?
  • Outcome: Advice given: consult Treasury Regulation section 1.168(k)-1(b)(4)(iii)(A).
  • Key authorities: IRC § 168(k); Treas. Reg. § 1.168(k)-1(b)(4)(iii)(A).

Full text (IRS public release)

ID: CCA_2009040915303157 Number: 200922033
Release Date: 5/29/2009
Office: ------------
UILC: 168.36-00

From: ------------------
Sent: Thursday, April 09, 2009 3:30:32 PM
To: --------------------
Cc: ------------------
Subject: RE: Regs. under 168(k)

--------- -- the term "self-constructed" property is defined in 1.168(k)-1(b)(4)(iii)(A).

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