Your client, Totally Toys, is a toy manufacturer. For several years, the company buried empty paint cans on its property. The paint was used in the...

Your client, Totally Toys, is a toy manufacturer. For several years, the company buried empty paint cans on its property. The paint was used in the production process. Recently, a state environmental agency informed the company that it was required to dig up the paint cans and decontaminate the land. The company spent a substantial amount for this cleanup in the current year. An IRS agent contends that the cost must be added to the basis in the land because the cleanup improved the land. The company’s CFP has asked you to determine if any authority exits that would support a current deduction for these costs.