Ivins, Phillips & Barker wrote on behalf of their clients in response to Notice of Proposed Rule Making REG-168745-03, requesting comments from interested parties regarding temporary and proposed regulations under sections 162, 168, and 263(a) of the Internal Revenue Code, concerning the distinction between deductible repairs and capital expenditures, as well as related subjects concerning the treatment of materials and supplies and the grouping and disposition of depreciable assets. A copy of this letter is enclosed.

IPB Letter to IRS/April 9, 2012