Land Improvement Decisions
Site work is often 15-year property. Land is not depreciable. Courts have applied the Whiteco questions to signs, vineyard systems, lawn sprinklers, and apartment site features — with results that split on the facts.
Educational information, not tax advice.
Updated 2026-10-14
Key takeaways
- Asset class 00.3 land improvements are generally 15-year MACRS property and exclude buildings and structural components.
- Whiteco held outdoor signs on concrete-set poles were personal property, not inherently permanent land improvements.
- AmeriSouth treated gate components and irrigation outlets as 15-year land improvements on that apartment record. Metro treated lawn sprinkler heads as part of an inherently permanent structure.
- Educational information, not tax advice.
Land does not depreciate. Improvements to land — paving, sidewalks, curbs, fences, site lighting, and many landscaping installations that would be destroyed with a related depreciable asset — are often land improvements recovered over 15 years. Publication 946’s Appendix B class 00.3 is the usual citation. That class excludes buildings and structural components as defined in Treas. Reg. §1.48-1(e).
Whiteco Industries, Inc. v. Commissioner, 65 T.C. 664 (1975), is the outdoor-sign case. Poles in concrete did not make billboards inherently permanent land improvements. The signs were designed around short advertiser contracts and were routinely moved. Rev. Rul. 2003-54 later treated gasoline-pump canopies as 5-year property and their concrete footings as 15-year land improvements — another split between the thing that serves customers and the thing poured into the dirt.
Trentadue v. Commissioner, 128 T.C. 91 (2007), is the modern regular Tax Court opinion that applies Whiteco to agricultural site systems. Research and the audit guide table report that vineyard trellises were not permanent land improvements, while buried drip irrigation and a well were land improvements because substantial piping was hard to remove. The inventory URL for Trentadue timed out on this pass, so those results stay conservative and are flagged. Do not treat the case as a rule that every irrigation system is 15-year property.
AmeriSouth XXXII, Ltd. v. Commissioner, T.C. Memo. 2012-67, shows apartment site lines. The Commissioner conceded that gate components were 15-year land improvements, as were a duplex outlet and timer related to watering the grounds. Water-distribution, sanitary-sewer, gas, and site-electric systems that served the buildings were kept with the complex or treated as non-depreciable to the extent the partnership did not own them. Metro National treated lawn sprinkler heads as part of an inherently permanent structure, which is why a sprinkler head is not automatically 15-year personal property.
Parking structures are buildings in the retail matrix, not land improvements. Exterior pools on land appear as 15-year items in some matrices; interior pools attached to a building stay with the building. Super Intelligence is proposed only. This page is educational information, not tax advice.
What stays with the building
The retail matrix treats parking garages and ramps as 39-year buildings. Building-mounted site lighting and attached trash enclosures often stay with the structure in examiner maps. AmeriSouth’s underground utilities that served apartments did not become 15-year property merely because they were outside the slab.
Source limit
Trentadue’s full opinion was not retrieved from the inventory URL. Whiteco, AmeriSouth, and Rev. Rul. 2003-54 were opened or already verified. See flags-cases.md.
How to use this page
Remove land first. Then ask whether the remaining site item is a building or structural component, a class 00.3 land improvement, or personal property. Whiteco’s signs were personal property despite concrete. Metro’s lawn heads were treated as part of an inherently permanent structure. AmeriSouth’s gates and irrigation timers were conceded as 15-year land improvements, while site utilities that served apartments stayed with the complex or dropped out for lack of ownership.
Trentadue is the agricultural Whiteco application reported in the audit guide — trellises one way, buried irrigation and a well the other. Until that opinion is opened from a working URL, do not add vineyard facts beyond that conservative split. Parking garages remain buildings on the retail examiner map, not land improvements.
Educational information, not tax advice.
Limits and flags
Land is not depreciable. Class 00.3 excludes buildings and structural components. Whiteco’s signs were personal property on a five-year-contract, routinely-moved record; they are not a rule that every pole in concrete is 5-year property. Metro’s lawn heads were treated as part of an inherently permanent structure. AmeriSouth’s gates were conceded as 15-year land improvements on that apartment record (flag F-11).
Trentadue’s inventory URL timed out. The vineyard split (trellises versus buried irrigation and a well) stays conservative and flagged. Parking structures remain buildings on the retail examiner map. Rev. Rul. 2003-54’s gasoline-pump canopy versus footing split is a ruling on those canopies, not a template for every canopy.
Super Intelligence is proposed only. Educational information, not tax advice.
Practice note
Site work fails in three ordinary ways. The item is still land (not depreciable). The item is a building or structural component (parking garage, building-mounted light, apartment sewer that serves the dwelling). Or the item looks movable but the record shows an inherently permanent system, as Metro’s lawn heads did.
Whiteco still helps a sign or a light pole that has actually been moved and was designed around a short contract. It does not pull a buried well or a garage ramp into 5-year property. AmeriSouth’s conceded gates and irrigation timers are 15-year examples on an apartment record, not a template for every fence. Until Trentadue’s opinion opens, keep vineyard facts at the conservative ATG split. Parking garages and ramps remain buildings on the retail examiner map, not class 00.3 land improvements. Educational information, not tax advice.
Sources
- 1IRS Publication 946 — How To Depreciate Property (2025)(opens in a new tab)
Appendix B reproduces the Rev. Proc. 87-56 class lives.
- 2IRS Publication 5653 — Cost Segregation Audit Techniques Guide (rev. 2-2025)(opens in a new tab)
Written for IRS examiners. The guide states it is not an official pronouncement of law and cannot be cited as authority. It predates the July 2025 law.
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- 6Metro National Corp. v. Commissioner, T.C. Memo. 1987-38(opens in a new tab)
IRS written determination that summarizes the decision.
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