A study is not always worth running. These are the conditions that stop
one. Feasibility exists to find them before you have paid for anything.
Hold period
You sell inside a few years
The 5-, 7- and 15-year property a study creates is section 1245
property. On sale, the depreciation taken comes back as ordinary income. A short hold
can hand back most of what the study moved forward, at a rate higher than the one that
saved it.
IRC §1245 · Treas. Reg. §1.1245-3
Passive losses
The deduction has nowhere to go
Passive losses do not offset ordinary income. Section 469(c)(7)
frees a qualifying real estate professional — more than half of personal services in
real property trades or businesses, and more than 750 hours in the year. Short of that
test, the deduction waits.
IRC §469(c)(7) · Treas. Reg. §1.469-9
Basis
There is not enough building to divide
A study costs about the same whether the property is small or
large. Below a certain basis the fee outruns the deferral. This is the first thing
feasibility checks and the most common reason we decline one.
Arithmetic, not law
Land
Most of what you paid was dirt
Land does not depreciate. A high land allocation leaves a thin
depreciable basis, and the short-lived components are a share of what is left. Move the
land slider on the estimator and watch the deferral fall.
Arithmetic, not law
Tax posture
There is no tax to defer
A deduction needs income to sit against. An entity already at a
loss, or an owner who pays no tax, gains nothing this year and carries the deduction
forward at a discount to what it would have been worth.
Arithmetic, not law
The asset
The building is plain
A bare shell with little site work, no dedicated power and no
finish carries a small share of short-lived assets. Warehouses sit at the bottom of
every range for this reason, and a plain one can sit below it.
Arithmetic, not law
Every one of these is checked before an engagement, in writing. A study we
would not run is a study we say no to.