Norwest Corporation And Subsidiaries v. Commissioner

108 T.C. 265 (1997)

Facts

P built a building with asbestos materials as its main fire retardant. P then decided to remove that material in coordination with an overall remodeling project. P wanted to deduct the asbestos removal as an ordinary and necessary business expense under 162(a). The Commissioner determined that the cost was all part of the general improvements to the building and held them as capital costs and to so be deducted.