25 January 2023

HVAC contractor entitled to IRC Section 179D energy tax deduction allocated by building owner, Tax Court holds

In a T.C. Opinion, the Tax Court has held that a heating, ventilation and air conditioning (HVAC) contractor is entitled to a $305k IRC Section 179D deduction because the HVAC system the company installed in a Veterans Administration (VA) building constituted "energy efficient commercial building property" under IRC Section 179D(c)(1) and a VA official had properly allocated the available IRC Section 179D deduction to the HVAC contractor. (Michael Johnson, et al. v. Commissioner, 160 T.C. No. 2.)

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ATTACHMENT

Michael Johnson v. CIR

Document ID: 2023-0157