[Code of Federal Regulations]
[Title 26, Volume 8]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.822-6]

[Page 710-711]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
Determination of Tax Liability--Table of Contents
 
Sec. 1.822-6  Real estate owned and occupied.

    Section 822(d)(1) provides that the amount allowable as a deduction 
for taxes, expenses, and depreciation on or with respect to any real 
estate owned and occupied in whole or in part by a mutual insurance 
company subject to the tax imposed by section 821 shall be limited to an 
amount which bears the same ratio to such deduction (computed without 
regard to this limitation) as the rental value of the space not so 
occupied bears to the rental value of the entire property. For example, 
if the rental value of the space not occupied by the company is equal to 
one-half of the rental value of the entire property, the deduction for 
taxes, expenses, and depreciation is one-half of the taxes, expenses, 
and depreciation on account of the entire property. Where a deduction is 
claimed as provided in this section, the parts of the property occupied 
and the parts not occupied by the company, together with

[[Page 711]]

the respective rental values thereof, must be shown in a statement 
accompanying the return.

[T.D. 6610, 27 FR 8722, Aug. 31, 1962]