- 30 - Petitioners purchase a towboat, including the engines, with the expectation that its useful life is 40 years. To achieve the expected useful life, petitioners regularly maintain the engines. They replace a relatively limited number of parts on a regular basis and inspect the vast majority of remaining parts, replacing only those that are worn beyond a certain tolerance. Petitioners also point out that two new engines would cost $1.5 million plus installation of approximately $200,000. If petitioners had replaced the two engines with overhauled or rebuilt engines, the cost would have been about $800,000. By comparison, the $100,000 maintenance is incidental when compared to the cost of an overhauled or rebuilt engine. If respondent’s perspective in this case were correct, the cost of a rebuilt engine would be more similar in cost to the maintenance performed by petitioners’ employees. Accordingly, the procedures performed here are routine maintenance that does not extend the expected 40-year life of the boat or engine. The procedures constituted preventative maintenance that permitted the engine to operate as intended by the manufacturer and the owner. Although it could be said that such procedures extended the life of the engine (in the sense that failure to perform them would have resulted in engine default) the life of the engine was not appreciably prolonged by these procedures. Considered in a vacuum, a $100,000 cost forPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011