as per a conversation with Joe Smith at Highland Golf Club on April 1, the facts are as follows: Highland Golf Club restructed their golf course's greens after withstanding severe hurricane damage. the improvements included installing computer-controlled irrigation and drainage systems. the prior cost of constructing the golf course's "natural" greens, without any dedicated irrigation system or other technology, was capitalized to the cost of the land and therefore has not been depreciated for either book or tax purposes.

issue: how should Highland Golf Club account for the recent greens restructuring costs for tax purpose?

please us the format of tax research memorandum.

Facts:

Issues:

conclusion:

analysis:

summary:

Authorities: 167; 168; Federal Tax Regulation 1.167(a)-2; Rev. Rul. 2001-60, 2001-51