Rev. Rul. 57-30

A taxpayer maintains a slip and dock which are used by ships delivering materials used in connection with the conduct of his business. At the time of its construction, the sides were riprapped, but operations subsequently have disclosed that due to the propeller action of the ships using the slip the riprap does not stay in place, thus requiring the taxpayer to incur substantial annual expenditures for maintaining the dock in a fully usable condition. In order to remedy the situation and to virtually eliminate the annual maintenance costs, the taxpayer had the slip on the dock side sheet-piled. The cost of the sheet piling was approximately three times the amount previously expended annually for maintenance. The sheet piling will be a permanent improvement to the dock, the useful benefits from which will extend beyond the taxable year. Held , the expenditure for sheet piling the slip constitutes a capital investment, within the meaning of section 263(a)(1) of the Internal Revenue Code of 1954, which is recoverable, for Federal income tax purposes, through annual depreciation deductions over the useful life thereof, irrespective of the ultimate saving to be effected otherwise in the maintenance.