Capital Project Fund Eligibility Guidelines

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1 Schl District f Philadelphia Nvember 2008 Capital Prject Fund Eligibility Guidelines Intrductin:... 2 Clarificatin f terms... 3 Discussin n the difference between Capitalizatin and Expense... 4 Prjects and Activities that may be charged t Capital Funds (whether expensed r capitalized)... 4 Payrll Charges... 6 Supprt Functin Payrll Expenses that cannt be capitalized... 6 Appendices... 8 Appendix A - Recmmendatins... 8 Create Plicies... 8 Analyze and quantify financial implicatins... 9 Annual Budgeting t include analysis f allwable payrll expenses t Capital Fund...10 Establish Time Tracking mechanism...10 Perfrm peridic Weighted Average Life Calculatin...10 Appendix B Capitalizatin Plicy Cnsideratins...11 Expenses eligible fr capitalizatin...11 Expenses that may NOT be capitalized:...12 Appendix C - Capital Fund Eligibility Plicy Cnsideratins...13 Ptential Nn-Capitalized Expenses Eligible fr Capital Funds...13 Initial Startup csts specifically allwed by the Cmmnwealth f Pennsylvania f 14

2 Intrductin: The purpse f this dcument is t establish accunting guidelines fr expenditures related t Capital Assets. The discussins presented in the fllwing pages are intended t clarify tw distinct issues relative t the District s Capital Imprvement Plan. They are: - Allwable charges that may be charged t a Capital Prject Fund - Expenses that are eligible fr capitalizatin The Schl District f Philadelphia is cmmitted t maintaining a high degree f excellence in all matters relating t budgeting, financing, accunting and prject planning. As a public entity, we are bund by state and federal law, lcal acts, prfessinal standards, and generally accepted accunting principals. Because f the multiplicity f gverning bdies that affect the District, plicies and prcedures must be crafted s that the smetimes cnflicting guidelines are recnciled. Therefre, these Guidelines have drawn n principals prmulgated by varius authritative bdies, state law, utside cunsel, bnd cvenants, external auditrs and the practices f ther gvernmental bdies engaged in similar activities. These include: Gvernment Accunting Standards Bard (GASB) Varius publicatins including GASB 34 American Institute f Public Accunting Varius Publicatins Financial Accunting Standards Bard Varius Publicatins Gvernment Financial Officers Assciatin Varius Publicatins The Internal Revenue Service IRS Publicatin 4079, Tax Exempt Gvernment Bnds Cmpliance Guide The Cntrllers Office f the City f Philadelphia Audits and Memranda The Pennsylvania Department f Educatin Manual f Accunting and Related Financial Prcedures Cmmnwealth f Pennsylvania Lcal Unit Gvernment Unit Debt Act 2 f 14

3 Clarificatin f terms The terms Capital, Capital Funds, Capitalizatin and Expense are frequently misunderstd and ften used interchangeably. In reality, they each have independent meanings. This ften leads t cmmunicatin prblems and peratinal difficulties. With that in mind, the fllwing definitins have been established: Capital Asset - In general, Capital Asset refers t the expenditures assciated with the acquisitin, renvatin, cnstructin r imprvement f Schl District f Philadelphia (SDP) wned tangible assets. The utcme f the expenditures must result in tangible assets that have a cmpnent value that meets the SDP Capitalizatin threshld (currently $500 1 ) and have an estimated useful life f at least 1 year. These types f assets include land, imprvements t land, vehicles, machinery, equipment, wrks f art, etc. Persnal Prperty This is a subset f Capital Assets. Persnal Prperty refers t capital assets that are nt part f a capital prject (e.g. persnal cmputers, desks, cpy machines etc). They tend t be prtable and are nt related t the cnstructin r renvatin f a structure. Capital Prject This is a subset f Capital Assets. Capital Prjects tend t be much larger and mre cmplex than Persnal Prperty acquisitins. Capitalize This is an accunting term which refers t the prcess f gruping expenditures related t capital assets and bking them n the SDP Balance Sheet. Once the item is capitalized, an entry is als made in the FAS Gv Fixed Assets Accunting subsidiary system. FAS Gv is the system used by the SDP t track fixed assets fr financial statement purpses. The item is assigned an expected useful life and depreciated ver the length f that life. Nt all expenditures will be capitalized. Sme will be expensed. Capital Prject Fund The fund type used t accunt fr financial resurces t be used fr the acquisitin r cnstructin f majr capital facilities (ther than thse financed by prprietary funds and trust funds). Capital utlays financed frm general bligatin bnd prceeds shuld be accunted fr thrugh a capital prjects fund. [NCGA Statement 1 Paragraphs 10 & 26, as amended by NCGAS 6, Paragraph 13 and GASB34, Paragraph 69] Capitalizatin Threshld The dllar value at which the SDP elects t capitalize tangible r intangible assets that are used in peratins that have initial useful lives greater than 1 year Expense A pint in time expenditure that reduces the available balance f a fund, but des nt get recrded n the balance sheet. Nte that certain items may be expensed thrugh a Capital Prject Fund, but may nt be capitalized. 1 A prpsal t raise the capitalizatin threshld t $5000 is currently being prepared. 3 f 14

4 Discussin n the difference between Capitalizatin and Expense When the District expends mney fr any purpse, whether t pay the electric bill fr a schl, pay a teacher s salary r cnstruct a new schl building, thse payments are expensed. That is, a prtin f District funds are used up and are n lnger available fr ther uses. In the case f tangible assets (e.g. buildings, cmputers, televisins) and sftware thse expenses are captured, gruped and identified n the District s Balance Sheet. This prcess is called capitalizatin. All Expenditures are expenses but nt all expenses can be capitalized. Tw f the basic qualificatins fr capitalizatin are (1) the item is tangible and (2) the item will have a useful life f mre than ne year. Regular expenses required fr the nging peratins f the schl district, such as teacher s salaries, d nt result in a tangible asset and d nt have a useful life f mre than ne year (i.e. the teacher is paid fr the last tw weeks f wrk). Therefre, these expenses cannt be capitalized. Prjects and Activities that may be charged t Capital Funds (whether expensed r capitalized) A Capital Fund is simply the cllectin f mney t which expenditures fr a capital prject may be charged. The fund cnsists f mney that is set aside fr capital prjects. Hwever, nt all f the csts assciated with a capital prject are eligible fr capitalizatin (i.e. sme charges must be simply expensed). Csts that are nt directly attributable t a specific capital prject, but are capital prject related may be expensed t the Capital Fund (as ppsed t expensing t the Operating r sme ther fund). These csts will reduce the amunt f mney available in the Capital Fund but will nt be capitalized. The criteria t determine whether nn-capitalized expenses may be charged t a Capital Prject Fund are gverned by the fllwing: Bnd Cvenants and definitins If the mney fr the fund was raised via a Bnd Issue the dcumentatin fr each bnd issue must be reviewed t determine hw the funds are intended t be used. Fr example, the $109 millin dllar Bnd financed thrugh the Dauphin Cunty General Authrity states: Article 1-Definitins -Sectin 1.04 (d) - District Representatins - Page 3 The District will apply the Lan Amunt fr the purpse f financing the riginal cst f the acquisitin, cnstructin r installatin f the Capital Imprvements and Facilities identified n Exhibit 1 Attached heret. Nwhere in the dcumentatin are there any prhibitins against charging capital prgram related but nn-capitalized expenses t the fund. Furthermre, the exhibit referred t itemizes several csts that clearly cannt be capitalized (e.g. Minrity/Wmen Business Enterprise cmpliance mnitring). Disclsed Weighted Average Useful Life If the mney fr the fund was raised via a bnd issue the bnds are typically cllateralized by the Capital Assets which are created with the mney brrwed. Typically, an itemizatin f the prjects t be funded is part f the bnd dcumentatin. This itemizatin further estimates the useful life f each prject. Frm that, a weighted average useful life f the entire prject prtfli t be financed is calculated. As a rule, the weighted average useful life will be greater than the 4 f 14

5 repayment perid fr the bnds (e.g. Bnd Life is 30 years and Weighted Average useful life is 38 years). By definitin, a nn-capitalized expense has a useful life f zer (0) years. The nncapitalized expenses can reduce the weighted average useful life f the underlying assets. The District shuld mnitr the impact f nn-capitalized expenses charged t a capital prjects fund s that they d nt bring the weighted average useful life f the underlying assets t less than 120 percent f the payback time f the bnd (e.g. if the bnd is 30 years, then the weighted average useful life f the underlying assets shuld nt dip belw 36 years). IRS Arbitrage Rules If the mney was raised via Tax Exempt Gvernment Bnds The district may nt use the prceeds f capital prject bnd issues t fund nging peratins. This wuld therefre preclude the charging f daily peratinal expenses against the capital prject fund. Cmmnwealth f Pennsylvania Lcal Gvernment Unit Debt Act (Act f ) This is applicable if the mney fr the fund was raised via a Bnd Issue - This Act gverns the legal authrity and limitatins f the District t brrw funds. It further defines what a Prject is and the allwable csts f a prject: Allwable Capital prject csts: payments t cntractrs acquisitin f a prject r fr lands, easements, right and ther appurtenances deemed necessary fr the prject fees f architect, engineers, appraiser, cnsultants, financial advisrs, and attrneys incurred in cnnectin with the prject financing csts csts f necessary printing and advertising csts f preliminary feasibility studies and tests, cst estimates and interest n mney brrwed t finance the prject, if capitalized, t the date f cmpletin f cnstructin and, if deemed necessary, fr ne year thereafter, amunts t be placed in reserve funds, if any, reasnable initial wrking capital fr perating the prject and a prper allwance fr cntingencies certain insurance related t the capital prject cvering SDP risk n the prject Discussin with the District s Bnd cunsel has cnfirmed that the Act des nt preclude charging capital prgram related but nn-capitalized expenses t the Capital Prject Funds. Schl District Plicy The District s Capital Fund plicy shuld describe the philsphical basis f the SDP twards allwable expenditures (capitalized and nn-capitalized expenses) t the capital prject fund. This is particularly true fr capital related but nn-capitalized verhead and administrative expenses directly related t the Capital Imprvement Prgram. Accunting rules preclude the capitalizatin f certain types f expenses (see Supprt Functin Payrll Expenses that Cannt be Capitalized fr exclusins n page 7). Hwever, assuming these expenses d nt vilate any f the gverning cvenants f the funds (e.g. bnd cvenants, Federal rules, etc.), the District may allw them t be paid frm the fund, as lng as the expenses are treated cnsistently. 5 f 14

6 Whether r nt nn-capitalized expenses can be charged t a capital prject fund, unless therwise required r precluded by the gverning surces cited abve is largely a philsphical issue. There are n authritative references that spell ut which nn-capitalized expenses may be charged t a capital prject fund. Discussins with state and city financial areas have cnfirmed this. This determinatin shuld be made utside f discussins regarding whether an expense is eligible fr capitalizatin (i.e. added t the balance sheet). The relevant questin is: Can the expenditure be charged t the capital prject fund r shuld it be charged t the General r ther fund? In general the fllwing cnsideratins need t be included in this determinatin: 1. Is charging the expenditure t the capital prjects fund specifically disallwed by any legal r ther authrity? Bnd Cvenants Average Weighted Useful Life impact IRS Arbitrage Rules (Are we using tax exempt bnd prceeds t finance nging peratins that are nt reasnably assignable t a capital prject?) Cmmnwealth f Pennsylvania Lcal Gvernment Unit Debt Act Plicy 2. Is the expenditure clearly tied t the cmpletin f thse prjects identified in the District s Capital Imprvement Prgram? 3. Can these charges be readily supprted with sufficient dcumentatin t justify charging them t the capital prject fund? Payrll Charges A significant part f the csts assciated with the Capital Imprvement Prgram is District persnnel payrll and related payrll benefits. All f these expenditures are expenses. Hwever, nt all f these expenses can be capitalized. Therefre payrll expenses need t be examined frm tw distinct pints f view: 1. Can these payrll expenses be charged t the capital prject fund? 2. Can these payrll charges be capitalized? In general, payrll and related benefit expenses can be charged t a capital fund, prvided that thse persnnel are clearly engaged in activities related t the Capital Imprvement Prgram. As a practical matter, unless individuals track their time engaged in Capital Imprvement Prgram activities, it may be necessary t determine this n an all-r-nthing basis. That is, if the individual is engaged in capital related wrk 100% f the time, their salary and benefit related expenses may be charged t the capital prject fund. Otherwise, it shuld be charged t anther fund. Payrll and related benefits that may be capitalized are subject t mre stringent recrd keeping requirements. That is, in rder t capitalize them, the time must be clearly related t wrk spent n activities related t a specific capital prject. The expenses must be assigned at a prject level and the charges must be supprtable thrugh payrll r sme ther time tracking dcumentatin. In additin, the payrll dllars assciated with certain specified activities is explicitly precluded frm capitalizatin. They are listed belw: Supprt Functin Payrll Expenses that cannt be capitalized Executive Management Crprate Accunting Acquisitins Purchasing Crprate Legal 6 f 14

7 Office Management & Administratin Marketing Human Resurces Again, the abve payrll expenses cannt be capitalized. Hwever, depending n the Plicy and ther criteria previusly discussed, they may be charged t a capital prject fund. Direct Charge f Eligible Salaries Beginning in Fiscal Year 2008, the Schl District f Philadelphia (SDP) nw has the ability t direct charge full time regular salaries using the LDAT tables in advantage. All current capital guidelines and prcedures are still in effect, it is nly this part f the prcess that is changed. This utline belw recgnizes these new steps related t direct charging f eligible salaries t capital prjects: 1. A prject request is submitted upfrnt by facilities services t the SVP-Capital prgrams and the fllwing prcess begins upn apprval. 2. Funds are identified and set up by the Directr f the Capital Financial Management Unit. 3. The apprpriatin unit(s) and expense budget line(s) are created by the Directr Capital Financial management Unit and frwarded t the apprpriate staff. 4. The LDAT is created based n the prject(s) currently being wrked n by facilities by Directr Capital Financial management Unit and updated in Advantage. 5. The LDAT is reviewed and upladed int advantage by the Principal Financial Analyst in the budget ffice (mdified as new prjects cme n line r ff line). 6. A facilities resurce scheduler identifies emplyees wrking n the specific prject(s) and the number f days in the pay cycle by wrksheet (repeated until prject(s) are cmpleted) 7. The wrksheet is reviewed by the Directr f the Capital Financial Management Unit and upladed by Principal Financial Analyst OBM (repeated until prject(s) are cmpleted) 8. Mnthly mnitring begins as part f the verall mnitring prcess. If charges are deemed ineligible a request t transfer back t the perating budget is made by the Directr f the Capital Financial Management Unit t the Principal Financial Analyst in the budget ffice. 7 f 14

8 Appendices Appendix A - Recmmendatins The fllwing is a list f recmmended next steps: Create Plicies Capital Fund Eligibility Plicy The principals fr evaluating expenditures t be charged t the capital fund need t be defined s that previusly unrecgnized situatins can be evaluated. Clear indicatin f respnsibilities shuld be delineated and cdified. The District may als cnsider establishing a dllar threshld fr expenditures t be cnsidered eligible fr capital funding. Nte: This threshld shuld nt be cnfused with the capitalizatin threshld which states the dllar value at which expenditure may be capitalized. As a practical matter, it wuld be helpful t establish brad categries f prjects t which capital expenditures can be evaluated. The City f Philadelphia s Plicy Statement fr Expenditure Eligibility fr Capital Funding establishes the fllwing categries: Acquisitin- refers t the purchase f land, buildings r machinery Allwable csts include: cst r preparing plans and specificatins, btaining appraisals and legal assistance directly related t acquisitin. Planning studies that generate preliminary plans and acquisitin estimates. Equipment and machinery that have a useful life f 5 years and a cst f $7,500. Nte: PCs are specifically excluded frm Capital Funding. Vehicle purchases are excluded by Plicy fr purchase with Capital Funds Cnstructin refers t building, erecting r installing tangible assets that are wned by the City. Allwable csts include: cst r preparing plans and specificatins, btaining appraisals and legal assistance directly related t acquisitin. Planning studies that generate preliminary plans and acquisitin estimates. Cst f sil tests, bring and ther architectural r engineering tests When cnstructing new facilities, the cst f purchasing furniture and equipment t perate the facility (with a life expectancy f greater than 5 years). Site preparatin expenditures such as demlitin. The remval f and/r testing fr hazardus materials (including, but nt limited t PCBs and asbests) when directly related t an therwise eligible cnstructin prject. Imprvements refers t renvatin, rehabilitatin r recnstructin f buildings, structures, parkland, machinery, equipment r ther tangible assets wned by the City. This includes landscape and pathway imprvements t City wned public space. Imprvements must result in extending the useful life f the asset by at least 5 years and cst at least $7,500. Fr an imprvement t be eligible it must substantially increase the 8 f 14

9 asset value. Prjects which merely maintain r repair an asset cannt be funded thrugh lan prceeds. Allwable csts include: cst r preparing plans and specificatins, btaining appraisals and legal assistance directly related t acquisitin. Planning studies that generate preliminary plans and acquisitin estimates. Cst f sil tests, bring and ther architectural r engineering tests When cnstructing new facilities, the cst f purchasing furniture and equipment t perate the facility (with a life expectancy f greater than 5 years). Site preparatin expenditures such as demlitin. The remval f and/r testing fr hazardus materials (including, but nt limited t PCBs and asbests) when directly related t an therwise eligible cnstructin prject. Lan funds are specifically excluded frm use t clean and seal buildings. The City s plicy uses a $7,500 threshld fr capital funding eligibility. Please nte that the abve criteria d nt include certain expenditures that the District has designated fr Capital funding. Fr example, $8.9 millin fr vehicle prcurement is itemized in the recent Dauphin Cunty and SPSBA bnd issues. Als, the City s plicy nly allws capital funding fr asbests remval when it is part f a larger prject that therwise qualifies. Therefre, the District s Plicies must be geared twards its particular needs within the framewrk f the purpse fr which the capital funds were raised. Beynd the abve defining the types f prjects that can be cnsidered fr capital prject funding, the plicy shuld specifically identify thse District payrll charges that may be included. Capitalizatin Plicy This plicy shuld be a distinct and separate dcument. Its purpse is t clearly identify thse types f expenditures that can be capitalized and hw they are t be treated frm an accunting perspective. It des nt address in any way, funding cnsideratins fr the expenditures. The fllwing tpics shuld be included: Capitalizatin Threshld Definitin f Capital Asset Definitin f Persnal Prperty Definitin f Capital Prject Guidelines fr timing f Capitalizatin Descriptin f Expenses t be capitalized Cnstructin in Prgress Nn-Capitalized Expenditures Estimated Useful Lives fr asset Categries Depreciatin methd and calculatin Transfers and dispsals Inventry f sensitive Items Respnsibilities Analyze and quantify financial implicatins Based n the plicy criteria that are t be established, the District needs t perfrm and analysis f the financial/budgeting implicatins f any changes. The analysis shuld include: 9 f 14

10 A review f Payrll expenses budgeted fr Capital Prject Fund Quantificatin f ptential impacts f plicy changes t the Operating Fund Annual Budgeting t include analysis f allwable payrll expenses t Capital Fund As part f the Annual Budgeting prcess, individual salaries shuld be reviewed t determine: Overhead and administratin salaries charged t Capital Funds as expenses Estimated time allcatins by jb psitin that can be supprted thrugh time tracking system (t be capitalized) Establish Time Tracking mechanism Only thse payrll expenses that can be tied directly t a capital prject can be capitalized. This must be supprted by either payrll recrds r sme ther time tracking mechanism. Capturing this infrmatin allws the District t capitalize the expenses. This tends t maintain the disclsed weighted average useful life calculatins. Perfrm peridic Weighted Average Life Calculatin As nted previusly, the district needs t be aware f the impact f nn-capitalized expenses n the weighted average life calculatin presented in varius Bnd disclsures. Therefre, the weighted average life calculatin f the underlying assets needs t be mnitred. 10 f 14

11 Appendix B Capitalizatin Plicy Cnsideratins The fllwing Guidelines shuld be cnsidered when defining the SDP Capitalizatin Plicy. Expenses eligible fr capitalizatin If the csts are directly identifiable with the specific Prperty Plant & Equipment (PP&E) they may be capitalized. Otherwise they must be expensed as incurred. Directly Identifiable cst include nly: 1. Direct cst - r the District fr a specific capital prject that will result in a tangible asset with a useful life f at least 1 year. These csts include: - purchase price f land, cnstructin materials, machinery and equipment. - external cnsulting csts - travel csts incurred in cnnectin with activities relating t the acquisitin, cnstructin, r installatin f PP&E - rental csts f equipment used in cnstructin, r installatin f PP&E - equipment installatin csts by a cntractr - sales and use taxes n materials r services purchased - imprt duties - freight and transprtatin-related insurance (fr example, a rider resulting in a premium increase). i 2. Payrll and Payrll Benefits and related csts (e.g. health insurance) directly related t the cnstructin, installatin, r ther necessary activities required t prepare the capital asset fr use that are perfrmed by SDP Persnnel r independent third party cntractrs. These csts can nly be capitalized t the extent f time the emplyees spent directly n the capital prject and in prprtin t the ttal hurs emplyed (including cmpensated absences). Payrll csts must be tracked t specific prjects using a time tracking mechanism that identifies the specific time and activities related t the prject. If apprpriate time tracking is nt maintained, then the csts cannt be capitalize and must be expensed. 3. Additinal Csts during the cnstructin phase- the fllwing additinal csts may be capitalized: Depreciatin f machinery and equipment used directly in the cnstructin r installatin f PP&E during the time it is directly being used fr the prject. Prperty taxes Grund rentals shuld be capitalized fr the prtin f the prperty under cnstructin, during the time that activities that are necessary t get the asset fr its intended use are in prgress. Insurance Allcatins - shuld be capitalized fr the prtin f the prperty under cnstructin, during the time that activities that are necessary t get the asset fr its intended use are in prgress. Interest n Bnds during the time f cnstructin f the PP&E. 11 f 14

12 Expenses that may NOT be capitalized: General Administrative and Overhead Csts must be expensed as incurred. These items include the fllwing types f expenditures: ii Rent fr physical space ccupied by emplyees Depreciatin f machinery nt used directly in the cnstructin r installatin f the PP&E. Other ccupancy csts f the physical space ccupied by emplyees All csts including fully laded payrll f supprt functins. Supprt functins include: Executive Management Crprate Accunting Acquisitins Purchasing Crprate Legal Office Management & Administratin Marketing Human Resurces 12 f 14

13 Appendix C - Capital Fund Eligibility Plicy Cnsideratins The fllwing Guidelines shuld be cnsidered when creating the SDP Capital Fund Eligibility Plicy. Ptential Nn-Capitalized Expenses Eligible fr Capital Funds Legitimate Capital related csts may be charged t the Capital Prject Fund regardless f whether they are capitalized r nt. Therefre the District needs t establish Guidelines fr thse items that may be charged t the Capital Prject Funds. Csts that shuld be evaluated include: Nn-capitalized salaries capital prgram executive salaries capital prgram supprt persnnel salaries ther nn-capitalized salaries Renvatins required t maintain building cde standards Lead Abatement Csts Asbests remval/cntainment Water Quality Other capital expenditures resulting frm gvernment mandated prgrams Leased equipment (e.g. PCs) reserves and cntingencies, Initial utfitting f a schl (e.g. supplies, bks etc.) Csts assciated with prjects that have been abandned Legal fees in regard t bnd issuance Title insurance csts Cnsultant csts fr bnd issuance Initial Startup csts specifically allwed by the Cmmnwealth f Pennsylvania Current state law allws capital funds t be used fr all csts assciated with the initial peratin f a building and the fixed assets cntained therein in rder t bring the asset t a state f usefulness. Hwever, many such items are nt capital assets by definitin. Therefre, they must be expensed. These include: General Educatin supplies Cmputer material supplies Afterschl activity supplies Office Supplies Business machine supplies Custdial Supplies Building Maintenance supplies Medical supplies Cnsumable supplies Nn Cnsumable supplies Miscellaneus supplies In additin, the fllwing items are allwable under the Cmmnwealth f Pennsylvania chart f accunt expenditure definitins and cnditinal usage f capital funds as cntained in bnd issues. Many f the fllwing csts typically wuld nt be capitalized if they fall belw the capitalizatin threshld. Hwever, if these are part f the initial startup csts f a new schl r facility, they can be tracked at a prject level 13 f 14

14 and capitalized regardless f the dllar amunt. These items may nly be charged t a capital fund fr the startup f a new schl building. Textbks Library bks Curses f study Instructinal Aids Educatinal Sftware Furniture & Furnishing Office Equipment Educatinal Equipment Maintenance Equipment Schl Cmputer Equipment Admin Cmputer Equipment Cafeteria Equipment i AICPA Prpsed Statement f Psitin: Accunting fr Certain Csts and Activities Related t Prperty, Plant, and Equipment ii AICPA Prpsed Statement f Psitin: Accunting fr Certain Csts and Activities Related t Prperty, Plant, and Equipment 14 f 14

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