https://www.irs.gov/Businesses/Capitalization-v-Repairs-Audit-Technique-Guide
The following table summarizes many of the factual considerations considered by the courts. These factors, although not exhaustive, should be considered in your analysis to distinguish between capital expenditures and deductible repairs.
Capital | Repair |
Improvements that “put” property in a better operating condition | Improvements that “keep” property in efficient operating condition |
Restores the property to a “like new” condition | Restores the property to its previous condition |
Addition of new or replacement components or material sub-components to property | Protects the underlying property through routine maintenance |
Addition of upgrades or modifications to property | Incidental Repair to property |
Enhances the value of the property in the nature of a betterment | |
Extends the useful life of the property | |
Improves the efficiency of the property | |
Improves the quality of the property | |
Increases the strength of the property | |
Increases the capacity of the property | |
Ameliorates a material condition or defect | |
Adapts the property to a new use | |
Plan of Rehabilitation Doctrine |