the amount is far in excess of the De Minimis safe harbor amount and the Safe harbor election for small taxpayers.
thus other rules apply
What is the facts and circumstances analysis for distinguishing capital improvements from deductible repairs?
Step 1 – What is the unit of property to which you should apply the improvement rules?
For buildings – The unit of property is generally the entire building including its structural components. However, under the final tangibles regulations and for these purposes only, the improvement analysis applies to the building structure and each of the key building systems.
***********
Step 2 – Is there an improvement to the unit of property, or in the case of a building, the building structure or any key building system, identified in Step 1?
A unit of tangible property is improved only if the amounts paid are:
To restore the unit of property;
*********************
What are amounts to restore a unit of property?
Replacement of a major component or substantial structural part – Amounts paid for the replacement of a part or combination of parts that make up a major component or a substantial structural part of the unit of property;
Therefore, I conclude that this is a capital expenditure and not eligible to be deductible as a repair
