Recent Projects

When a major hospital healthcare provider needed help in supporting claims for items of tangible personal property treatment on acquisitions and facility expansion projects, our cost segregation experience put us in the spotlight.

Over a period of years, the taxpayer had made a number of total hospital facility acquisitions and subsequent facility enhancements. Each of these projects was studied for the allocation of the purchase price and/or construction cost segregation on the enhancement projects. However, when pressed by the IRS for support, the vendors of these services were unable to satisfactorily answer the request.

N-RA has in its background, the expert witness experience in the Hospital Corporation of American vs. Commissioner of Internal Revenue, 109 TC No. 2, a precedent setting tax court case which addressed the use of tests developed under prior law for purposes of the investment tax credit, as applicable to the determination of the tangible personal property for federal tax depreciation purposes.
As tax court recognized expert witnesses and the court's acceptance of our procedures and methods, our credentials have already been established. This recognition gives direction to our pretrial accumulation of the physical facts and allows the litigation team latitudes in the presentation procedures. We will go to court with proven procedures and presentations which have been enhanced by our subsequent experiences.