The rules as to what is a “repair” and, therefore, is deductible, and what must be capitalized and depreciated have never provided a bright line for determining how an expense should be handled. The cases have not always been consistent which is not unexpected when the facts and circumstances of each case are controlling. Two cases, one in 2000 and another in 2003 have provided useful guidance on where the line should be drawn between repairs and expenses that must be capitalized.
Harl, Neil E.
"Repair or Capitalize Expenditures?,"
Agricultural Law Digest: Vol. 14
, Article 1.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol14/iss23/1