Reviewed Case Index
An index of the court decisions CostSeg SI has source-checked for this library, with weight and limits noted. It is not a complete survey of all depreciation cases, and it is not titled “recent” because the core opinions are decades old.
Educational information, not tax advice.
Updated 2026-10-14
Key takeaways
- HCA, Whiteco, Scott Paper, and the Supreme Court capitalization and basis cases are the core authorities in this library.
- AmeriSouth and Peco Foods are the modern caution cases. They have no named inventory URLs (flag F-21).
- Four inventory captions are not cost-segregation classification cases. Their pages state the decision that was opened and the limit (flag F-06).
- Educational information, not tax advice.
This index lists decisions that were opened or confirmed against IRS materials during CostSeg SI’s 2026 research and the 2026 article expansion. It is not titled “recent” because several of the most important opinions are decades old. Recency is not what makes a case relevant. Regular Tax Court and Supreme Court opinions carry more weight than memorandum opinions. Circuit splits exist, especially on electrical allocation.
Use the named case pages for Hospital Corporation of America, Whiteco Industries, Commissioner v. Idaho Power Co., Commissioner v. Lincoln Savings & Loan, Massey Motors (historical), Estate of Walling, Scott Paper, Plainfield-Union Water Co., Simon (low building relevance), Metro National (partial sources), and Alamo Broadcasting (historical). Four other named pages explain a mismatch: L.A. Darling Co. v. Commissioner was not found as a company tax opinion; Sperry and Hutchinson is an Oregon interest-apportionment case; Clemens is a sick-leave exclusion; Yellow Cab Co. v. Commissioner is an excess-profits case, with a different Pittsburgh caption for idle cabs. None of those four classifies building components.
AmeriSouth XXXII, Ltd. v. Commissioner, T.C. Memo. 2012-67, and Peco Foods, Inc. v. Commissioner, T.C. Memo. 2012-18, aff’d No. 12-12169 (11th Cir. 2013) (unpublished), are real authorities. The inventory does not give them named routes. They are discussed on topic pages and on acquisition tax-law pages. Do not invent /court-cases/amerisouth or /court-cases/peco URLs.
Topic pages collect holdings by issue: structural components, personal property, building systems, electrical allocation, plumbing and HVAC, specialized equipment, land improvements, decorative features, functional interdependence versus allocation, permanent attachments, cost-estimation evidence, depreciation basis, and repairs versus capitalization. Pre-1987 decisions in those pages are mostly investment-tax-credit cases. They remain relevant because HCA held those tests apply under MACRS — not because an ITC result is an automatic MACRS outcome.
Super Intelligence is described on CostSeg SI only as a proposed way to organize facts against these authorities. No page in this library claims that an unverified agent is operational. This index is educational information, not tax advice, and nothing in it has been expert-reviewed.
Decisions discussed but not given their own URL
AmeriSouth XXXII, Ltd. v. Commissioner, T.C. Memo. 2012-67 (most apartment components remained 27.5-year property; a short list of site and dedicated-equipment items survived).
Peco Foods, Inc. v. Commissioner, T.C. Memo. 2012-18, aff’d No. 12-12169 (11th Cir. 2013) (unpublished) (written §1060 allocations bind both parties).
Morrison, King Radio, A.C. Monk, Boddie-Noell, L.L. Bean, Shoney’s South, Trentadue, FedEx, and INDOPCO appear on topic pages with the sources that were confirmed. Texas Instruments and Duaine remain table-level or secondarily described where the opinion text did not open.
Captions that are not classification cases
L.A. Darling, Sperry & Hutchinson, Clemens, and Yellow Cab Co. v. Commissioner now have pages. Each page names the decision that was opened and says it does not classify building components. They are in the sitemap with the rest of this library. Do not cite them for a 5-year or 15-year class.
How to use the library
Read the named page for the legal test. Read the topic page for the comparison set. Read the verification note for what was actually opened. Do not treat a matrix row or a single memorandum as a nationwide rule that an asset “is” 5-year or 15-year property.
Opinions that did not fully open — Shoney’s, Trentadue, the Texas Instruments memorandum, and Metro’s memo text itself — are flagged in docs/_audit_work/flags-cases.md. Those pages stay conservative. Publication status, sitemap, robots, and REQUIRE_EXPERT_REVIEW were not changed. No page is marked expert-reviewed.
Educational information, not tax advice. Super Intelligence is proposed only.
What this index is not
This page is a reading order, not a holding. AmeriSouth and Peco are discussed on topic pages and in named-case relevance notes; they have no named inventory URLs (flag F-21). L.A. Darling, Sperry and Hutchinson, Clemens, and Yellow Cab are written as mismatch pages: the opened decision is described, and it is not offered as a cost-segregation class (flag F-06).
Whiteco’s six factors are a Tax Court test, not a statute. Scott Paper’s electrical allocation is mill-specific; IRS acceptance language does not extend to plumbing or HVAC (flag F-09). Boddie-Noell and A.C. Monk are forum-limited per the audit guide. Massey and Alamo are historical useful-life cases (flag F-15). Present every outcome as fact-specific (flag F-10).
Super Intelligence is proposed only. Educational information, not tax advice.
Practice note
Read named pages for the legal test and topic pages for the comparison set. HCA plus AOD 1999-008 is the MACRS classification starting point. Whiteco is permanence. Scott Paper and Morrison are electrical allocation, with A.C. Monk as the Fourth Circuit counterweight. Lincoln Savings, INDOPCO, and Treas. Reg. §1.263(a)-3 are capitalization. Idaho Power and Peco are basis.
Opinions that did not fully open stay conservative: Shoney’s, Trentadue, Texas Instruments, and Metro’s memorandum text. AmeriSouth and Peco are discussed without new routes (flag F-21). The four mismatch captions are filled only with the decisions that were opened. Publication, sitemap, robots, and REQUIRE_EXPERT_REVIEW were not changed. This library was not marked expert-reviewed. Educational information, not tax advice.
Sources
- 1
- 2IRS Publication 5653 — Cost Segregation Audit Techniques Guide (rev. 2-2025)(opens in a new tab)
Written for IRS examiners. The guide states it is not an official pronouncement of law and cannot be cited as authority. It predates the July 2025 law.
- 3
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- 6