The rapid turnover of the high-volume, low-cost items in these businesses makes it difficult to track them on an item-by-item basis and they are generally deducted when placed in service even though the economic useful life of specific items might last from 12 to 18 months.
Although there are clearly disputes about the life and timing of deductions for repairs to tangible, "hard" assets as well, the scope and frequency of the controversies are far less than for intangibles because engineering studies, industry practices, and taxpayer experience supply empirical guidance on the economic useful life for tangibles.
TABLE 1 Failure Rates Versus Economic Useful Lives of Septic Systems Annual Failure Rate Economic Useful Life
The court should determine whether the economic useful life of the component part is co-extensive with the economic useful life of the larger unit of property.
Finally, the court said that it was concerned primarily with the economic useful life of FedEx's aircraft, a term that the aviation community defines as "the period of time over which it is (or expected to be) physically and economically feasible to operate (both aircraft and engines) in their intended role.
If so, the economic useful life
of the unit of property is the depreciable life reflected on the applicable financial statement, unless the taxpayer can show by "clear and convincing evidence" that a shorter useful life is appropriate.
According to industry standards, the economic useful life
of a properly maintained aircraft is approximately 30 years.
However, in nontax shelter situations, if taxpayers intend to hold the contributed property for most or all of its economic useful life
(and not sell the property in the second year), a gain chargeback provision may provide a "reasonable basis" (within the meaning of Sec.
In this formula, the present value of the FMV rent for the lease term is presumed to be less than the FMV of the tangible property when the lease term is shorter than the tangible property's economic useful life