Pa. Brown et Ph. Mills, Impact fees and publicly dedicated improvements: Are they really nondepreciable intangibles?, J REAL EST, 28(4), 2001, pp. 361-374
Treating dedicated improvements or even impact fees (which indirectly provi
de similar benefits) as not part of the basis for property developed and pl
aced in service by a taxpayer is inconsistent with case law, the purpose of
Section 263A, and the Section 460 treatment of long-term contracts.