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CHIEF COUNSEL
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
September 28, 2001
Number: 200202026
Release Date: 1/11/2002
CC:LM
UILC: 162.16-04 POSTS-150002-01
263.14-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR ALL AREA COUNSEL (LARGE AND MID-SIZE BUSINESS)
AND AREA COUNSEL (SMALL BUSINESS/SELF
EMPLOYED)
FROM: Linda Burke
Division Counsel (Large and Mid-Size Business) CC:LM
SUBJECT: Airframe Heavy Maintenance Visit
This is to alert all Area Counsel about the attached guidance for examiners issued
June 8, 2001, by the Industry Director, Heavy Manufacturing and Transportation
regarding the proper tax treatment of cyclical heavy maintenance visits on aircraft
airframes.
Please contact Dave Lumbreras, Air Transportation Technical Advisor,
LMSB:PFTG:Gr2, at (972) 308-1569 or Dave.C.Lumbreras@irs.gov, or Hugh
Whitledge, Associate Technical Advisor, LM:PFTG:TA:Team 2, at (972) 308-7016
or Hugh.D.Whitledge@irs.gov, if you have any further questions.
Attachment
As stated
2
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
June 8, 2001
Large and Mid-Size
Business Division
MEMORANDUM FOR DIRECTORS, FIELD OPERATIONS, HEAVY MFG., &
TRANSPORTATION
DIRECTOR, FIELD SPECIALISTS
DIRECTOR, PREFILING AND TECHNICAL GUIDANCE
FROM: Thomas J. Smith
Industry Director, Heavy Manufacturing and Transportation
SUBJECT: Field Guidance on the Planning and Examination of the
Heavy Maintenance Visit (HMV) on Airframes
The purpose of this memo is to provide guidance to examiners in the audit of the
Airframe Heavy Maintenance Visit issue in light of the publication of Revenue
Ruling 2001-04. This is not intended to be a technical position but to provide audit
issue direction to effectively utilize our resources.
Revenue Ruling 2001-04 (2000 TNT 247) published December 22, 2000, provides
guidance as to the proper tax treatment of cyclical HMV on an aircraft’s airframe.
The Ruling presents three factual situations numbered 1, 2, and 3. Following an
analysis of the applicable legal authorities, the ruling concludes that the costs
incurred to perform an HMV generally are deductible as ordinary and necessary
business expenses under section 162. However, the costs incurred in conjunction
with an HMV must be capitalized to the extent they materially add to the value of,
substantially prolong the useful life of, or adapt the airframe to a new or different
use. With reference to the three situations presented in the ruling, situation 1 is
concluded to be entirely a deductible expense; situation 2 is concluded to have
four specific items requiring capitalization; and situation 3 is concluded to be
subject to the so-called "plan of rehabilitation" doctrine and, thus, entirely capital.
Some of the terminology used in the ruling (i.e. "significant portion", "substantial
structural part", "major component", or "material upgrade or addition") is
undefined. Pending clarification of these terms, this document is intended to
provide guidance to examiners on the efficient use of time and resources in the
examination of this issue. Based on the ruling, the commitment of staffing to
examine airframes, which underwent the first or second HMV, is usually not an
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effective utilization of those resources. The type of steps that should be taken in
planning and conducting an examination of the airframe issue are shown below.
Planning
At the beginning of an examination, you should contact the Air Transportation
Technical Advisor group and obtain a listing of the taxpayer’s fleet composition.
This will show you the type and age of all the aircraft (i.e. Boeing 727, Boeing 737,
DC-10, Airbus A320). This list can be shared with the taxpayer and used to
confirm the type and age of their fleet. From this, you will quickly see if the
taxpayer has an aging fleet that would be subject to a third HMV or a newer one
that would not be subject to it. If they have few aircraft subject to a third HMV,
you should not spend significant resources on this issue.
What do you do if the taxpayer has numerous planes that could be subject to a
third HMV?
1. Request a list identifying, by tail number if possible, each aircraft in the
taxpayer’s fleet that underwent a third or later airframe HMV during the years
under examination. The amount spent on each aircraft should be requested
along with a breakdown of the individual items making up the amounts
capitalized and expensed. From the perspective of the IRS, the preferred
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