Technical Compliance Library
SegFlow AI doesn't just automate reports; we automate compliance. Our resource hub provides the technical foundation required for high-stakes tax advisory and IRS audit defense.
IRS Cost Segregation Audit Techniques Guide
The official IRS publication providing comprehensive guidelines for cost segregation studies and audit expectations.
IRS Audit Readiness Checklist
A comprehensive internal audit checklist mapping directly to the IRS Audit Techniques Guide requirements.
Regulatory Framework & IRS Links
IRS Audit Techniques Guide (ATG) - 2025 Revision
The primary regulatory framework for cost segregation. Essential for understanding the 13 principal elements of a quality study.
Revenue Procedure 87-56 (MACRS Table B)
The definitive list of asset classes and recovery periods for MACRS depreciation (5, 7, 15, and 39-year properties).
Tangible Property Regulations (TPR)
Final regulations for Section 162 and 263(a) regarding the deduction and capitalization of expenditures related to tangible property.
Revenue Procedure 2022-14
Guidelines for Form 3115: Change in Accounting Method. Required for 'catch-up' depreciation on properties placed in service in prior years.
The SegFlow Quality Standard
Every report generated by SegFlow AI is built to exceed the 13 Principal Elements defined in the IRS Audit Techniques Guide. These standards ensure that your study stands up to the highest level of scrutiny.
Case Law & Precedents
Detailed engineering substantiation based on landmark Tax Court rulings.
Hospital Corp of America v. Commissioner
A landmark case that dismantled the IRS "component part" theory. The court ruled that building-integrated systems (electrical, plumbing, HVAC) could be Section 1245 property if they exclusively serve specialized medical equipment.
The court rejected the idea that any item attached to a building is part of the "structural shell."
This allows for the reclassification of power, vacuum, and air lines that support dental chairs, X-rays, and kitchen equipment.
Whiteco Industries, Inc. v. Commissioner
Established the "6-Factor Test" used to determine if an item is "inherently permanent" (Real Property) or "tangible personal property" (Personal Property).
The court provided a specific test for removability, attachment, and design intent.
The legal foundation for reclassifying walls, partitions, signs, and modular architectural features.
AmeriSouth XXXII Ltd. v. Commissioner
A critical case for residential property owners. The court scrutinized the classification of "personal property" in apartment complexes.
Reinforced that cabinetry and finishes must be clearly distinguishable from structural components to qualify for 5-year life.
Standardizes the quality of engineering evidence required for residential kitchen and bath reclassifications.
Revenue Procedure 87-56
Not a court case, but the definitive IRS framework for asset lives.
Provided Asset Class 00.11 through 80.0, defining the "Recovery Period" for every possible commercial asset.
The primary reference for assigning 5, 7, or 15-year lives to segregated components.
Technical Notice: One Big Beautiful Bill Act & IRS Focus Areas
The One Big Beautiful Bill Act (P.L. 119-21, signed July 4, 2025) permanently restored 100% bonus depreciation for property acquired and placed in service after January 19, 2025, and doubled Section 179 to $2.5M. With increased incentives, the IRS SB/SE division has signaled heightened scrutiny onPrimary Electrical Switchgear allocation,Land Improvement classification accuracy,Acquisition Date verification (Jan 19, 2025 cutoff for 100% vs. 40%), andQualified Production Property eligibility under new Section 168(n). SegFlow's engine is continuously updated to provide discrete engineering workpapers for these specific focal points.