(issue was whether petitioner, custom homebuilder, subject to I.R.C. Sec. 263A (which requires producers and retailers with gross receipts in excess of $10 million to capitalize tax depreciation exceeding financial statement depreciation, indirect labor and overhead costs attributable to production activities as part of cost of inventory or constructed property); petitioner claimed its activities were marketing and sales, rather than production-related due to custom nature of home built and work involved in building homes is subcontracted out and only has employees that perform services; court noted that creative design of custom homes merely ancillary to actual physical work on land and is the equivalent to digging foundation or completing structure's frame; capitalization required of specific costs attributable to production activities including part of owner's salary, employee bonuses, design costs, salaries for office employees, employee benefits, payroll taxes insurance and office expenses).