Category: Deductions and Credits
Subject: Depreciation
Title: Depreciation of Golf Course Components
IRC Sections: 167
Filename: 1042.html
Date Produced: 12/97

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Taxpayer operates a golf course and seeks to depreciate the cost of construction various components of the course such as greens, tees, etc.

On that subject, I was able to locate the following items.

The Edinboro Company v. U.S., 224 FSupp 301, 63-2 USTC ¶9759 (DC PA, 1963)

Revenue Ruling 55-290, 1955-1 CB 320.

Both the ruling and the case explicitly provide that the cost of constructing or purchasing various components of a golf course are not depreciable because these items are inextricably part of land.

These items, particularly Edinboro, are widely cited as standing for the proposition that golf course improvements are not depreciable. I can find no dissenting view in the entire tax literature.

Copies of the cited items follow.

Please call me when you have digested this material.