Question on Treatment of 1.263(a)-(f)(6) With Self-Renovations

[Benjamin Weinhart]

Hello, I'm mostly writing to confirm my suspicions as the regulations are a little unclear/I'd appreciate a second set of eyes to make sure I'm not completely off-base. I'm looking at the proper treatment of the de minimis safe harbor election 1.263(a)-(f), specifically paragraph 6 which details the anti-abuse rule. As an example, a taxpayer is completing their own renovations of a property to save a bit of money with the intention to rent out. Because of this, they're purchasing their own supplies/materials with very minimal labor expenses. It just so happens that none of the individual expenses exceeded the $2,500 rule even though the aggregate cost to construct a set of cabinets (example) may exceed this threshold.

Since 1.263(a)-(f)(6) specifies intent rather than the end result (Unless you think (6)(i) would apply), since the intent of the taxpayer was not to manipulate this election for a tax benefit, my assumption is that they would be able to expense all of the items normally.

Just looking for confirmation as I'm pretty confident my understanding of the regulation is correct. In the event I am wrong though and the anti-abuse rule would be triggered, I assume this would be treated normally under CIP rules?