Ingram Industries, Inc. & Subsidiaries - Page 23




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               Preliminarily, we consider the parties’ disagreement                   
          concerning whether a towboat engine should be considered                    
          separately from the towboat.  Respondent’s argument is                      
          constructed in a manner that focuses on the engines, which                  
          ostensibly provides better comparisons for his arguments by                 
          magnifying the cost of the procedures performed through a                   
          reduction of the scale of the asset being considered.                       
          Petitioners contend that, factually, there is no predicate for              
          treating the engine separately from the towboat.  Additionally,             
          petitioners argue that the result would not be changed by solely            
          focusing on the engines.  We agree with petitioners that the                
          record does not support a finding that, as a matter of industry             
          practice or otherwise, the engines are purchased or treated                 
          separately from the tow boats.  To the contrary, the life of a              
          towboat is 40 years, and it is expected that the engines, if                
          properly maintained, will also last 40 years.  Towboats are                 
          purchased with engines, albeit to the buyer’s specifications,               
          that are designed to be maintained without removing them from the           
          boat.  There was no showing that towboat owners regularly and               
          periodically over the life of the vessel replaced the engines.              
          Accordingly, we disregard any suggestion by respondent that the             











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Last modified: May 25, 2011