Hi, I'm picking up on this thread about MHP depreciation.
I'm close to getting my first MHP under contract and am trying to understand whether my project has any depreciation advantages or not. Assumptions:
- This park is 100% TOHs so no mobile homes to depreciate
- No clubhouse, other amenities, or real property to depreciate (the only structure is a small pump building)
- As far as existing infrastructure, the park is on well and septic (multiple systems), sewer/water lines, paved roads, electric to all pads--all that have considerable value when considering replacement costs
I've negotiated a below FMV purchase price directly with the current owner for the amount of the current assessed land tax value (and the tax assessment doesn't reflect any assessed land improvements (buildings) since they aren't any).
Here are the main questions with regard to depreciation:
1) If my purchase price is the same as the assessed land value, will I have any depreciable basis going into the project in the eyes of the IRS? I understand that future capital improvements would be depreciable but if none of the value of the existing infrastructure can be applied towards the basis, it obviously changes my after-tax returns significantly.
2) If the answer to question 1 is no, can I effectively create a defensible basis by getting a cost segregation done that breaks out the true value of the infrastructure or, would the appraisal suffice since the appraiser would presumably provide a breakout of the infrastructure value?
3) Could I improve my defense against a future IRS audit by including an allocation of the purchase price to land vs infrastructure (eg., 50/50 ratio) in the purchase sales agreement of the park, or does the fact the county land assessment equal the purchase price supersede that in the eyes of the IRS?
Thanks,
Joe