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petitioners’ towboats will push between 15 and 40 cargo-laden
barges with an average of 1,500 tons of cargo. For purposes of
comparison, a semitrailer truck holds about 26 tons of cargo, so
a barge carries the equivalent of 58 semitrailer loads of cargo.
During the taxable years in issue, a new towboat comparable to
the representative vessels cost approximately $6.25 million and a
used vessel cost approximately $2.2 to $2.3 million.
B. Towboat Configuration, Maintenance, and Valuation
The principal areas of a towboat are: The wheelhouse, the
upper deckhouse, the main deck, the upper engine room, the deck
stores area, the steering room, and three areas of the hull--the
fuel and ballast tanks, the main engine room, and the shaft
alley. A towboat is a very large, integrated item of machinery
comprised of a variety of components and systems, of which the
principal part is the propulsion system or engines and drive
train.
There are three basic groups of operational systems on an
inland river towboat: Those that perform the primary functions
of floating, maneuvering, and moving up and down the river (e.g.,
the engines, gears, clutches, steering systems, tailshafts and
propellers); those that support the primary systems (e.g., the
fuel system, the bilge system, the fire system, hydraulic
systems, ventilation systems, electrically powered auxiliary
systems, environmental systems, and others); and those that
support the crew and personnel operating the towboat (e.g., the
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