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.
After all, the economic useful life
for assets of the same age may differ.
TABLE 1 Failure Rates Versus Economic Useful Lives of Septic Systems Annual Failure Rate Economic Useful Life
(Years)* 1.0% 100 1.5% 67 2.0% 50 2.5% 40 3.0% 33 4.0% 25 5.0% 20 *Inverse of malfunction rate.
* 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." Obviously, periodic maintenance and repairs will usually be required to preserve safety and efficiency during the engine and airframe's economically useful life.
A cost also must be capitalized if it "substantially prolongs" the "economic useful life" of a unit of property.
The economic useful life of the unit of property is "substantially prolonged" under the proposed regulations if it extends the period over which the property may reasonably be expected to be useful to the taxpayer beyond the end of the taxable year immediately following the tax year in which the economic useful life of the property was originally expected to cease.
Certain activities are deemed to substantially prolong the economic useful life of a unit of property.
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
If curative allocations are "bunched" into a short time frame, they are less likely to be viewed as reasonable than if the partnership agreement requires them to be made over a less distortive time period (e.g., over the property's economic useful life