(a) Uniform capitalization rules generally require that
all costs incurred (both direct and indirect) in manufacturing or
constructing real or personal property, or in purchasing or holding
property for sale, must be capitalized as part of the cost of the
property. However, these rules do not apply to a “small retailer
or wholesaler” who acquires personal property for resale if the
retailer’s or wholesaler’s average annual gross receipts for the
three preceding taxable years do not exceed $10 million.