Ingram Industries, Inc. & Subsidiaries - Page 30




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          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 for              






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Last modified: May 25, 2011