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A taxpayer inquired whether the deduction of expenses and depreciation, as well as the imputation of income, should be based on the period the property was actually rented or the period it was available for rent. The DGT ruled that, as these are returns on real estate capital, expenses and depreciation are deductible only for the days the property was rented, whereas the imputation of income is calculated based on the days the property was not leased.
Question posed: It is inquired whether, for the determination of deductible expenses, as well as the imputation of real estate income corresponding to the apartment, account must be taken of the period during which it was effectively rented or the period during which it was available at the management company for rental.
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