Can proprtey taxes on 2nd home be capitalized ?

[RWG1950]

My customer's have been itemizing & deducting the property taxes paid on their 2nd home. For 2019 this puts them well over the $10K SALT cap.
In early 2020 they sold this property. Can the property taxes paid during 2019 be capitalized & added to their basis ?
If yes, how would this be done ? Thanks for comments.

[WICPA]

It's a good thought but I believe under Reg.1.266-1 you only are allowed to capitalize taxes and interest on unimproved land. I know I've always done it on unimproved land for state purposes even before the SALT caps.

[New York Enrolled Agent]

My customer's have been itemizing & deducting the property taxes paid on their 2nd home. For 2019 this puts them well over the $10K SALT cap.
In early 2020 they sold this property. Can the property taxes paid during 2019 be capitalized & added to their basis ?
If yes, how would this be done ? Thanks for comments.

The Tax Court has ruled that a taxpayer cannot use the capitalization on a personal residence. See Megibow 21 TC 197