Palmer Corporation just hired Mickey, golf pro, to develop and construct an eighteen-hole course in Wyoming. This is an extensive project that involves earthmoving costs to create a state-of-the-art landscape for the new course. Though the fairways have planted grass, the greens will be “modern greens” which involve complicated drainage systems. The greens must be replaced when the underlying drainage systems are replaced. Mickey seeks your advice as to which costs can be expensed and what costs can be capitalized either as part of the land or as depreciable assets as it relates to the fairways and the modern greens. He needs to know which costs can be expensed and which costs have to be capitalized.

Required:

Perform the necessary tax research and write a memo to the file on this issue. For any court case or Revenue Ruling that you cite as support for your conclusion please print the citatory table and submit it with your Memorandum to the File.