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an overhaul. These procedures in the case of the representative
engines, however, resulted in the replacement of 119 of the 576
major parts of the engines. In other words, approximately 79
percent of the parts are reused and approximately 21 percent
replaced. For an engine overhaul, substantially more parts are
automatically replaced to totally recondition the engine.
Respondent, however, seeks to have us focus on the fact that
the towboat engines are taken apart by 8 to 10 of petitioners’
employees and that it takes 10 to 12 days to inspect, handle,
clean, and/or replace the various engine parts. To respondent,
there is no difference between these procedures and an overhaul.
Petitioners, by way of illustration, however, point out that they
expend $100,000 (for parts and labor) to maintain a towboat,
which if purchased new would have cost $6.25 million during the
years in issue. That represents a 1.6-percent expenditure to
keep the most significant portion of the towboat operating
properly.7 If we were to assume that a new automobile cost
7 Petitioners chose to use the cost of a new towboat to make
the illustration more emphatic. However, if the cost of a used
towboat (approximately $2 million) is used, the cost-to-
maintenance ratio would be 5 percent ($100,000 divided by $2
million). If the cost of new engines is used ($1.5 million) the
ratio would increase to almost 7 percent ($100,000 divided by
$1.5 million). Finally, if the cost of a completely overhauled
or rebuilt engines is used ($600,000), the ratio would be almost
17 percent ($100,000 divided by $600,000). Ultimately, the
difference between the cost of the procedures to maintain
($100,000) and the cost of completely overhauled or rebuilt
engines($600,000) is more telling. Plus, there is also the extra
(continued...)
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