- 11 -
days in all periods of customer use of the property for the year
by the total number of periods of customer use for the year.
Sec. 1.469-1(e)(3)(iii), Income Tax Regs.
Section 1.469-1T(e)(3)(iv), Temporary Income Tax Regs., 53
Fed. Reg. 5702 (Feb. 25, 1988), defines significant personal
services as follows:
In determining whether personal services provided in
connection with making property available for use by
customers are significant, all of the relevant facts
and circumstances shall be taken into account.
Relevant facts and circumstances include the frequency
with which such services are provided, the type and
amount of labor required to perform such services, and
the value of such services relative to the amount
charged for the use of the property.
Significant personal services include only services
performed by individuals and do not include excluded services as
defined under section 1.469-1T(e)(3)(iv)(B), Temporary Income Tax
Regs., 53 Fed. Reg. 5702 (Feb. 25, 1988). As relevant herein,
excluded services are defined as services necessary to permit the
lawful use of the property and services performed in connection
with the performance of repairs that extend the property’s useful
life for a period substantially longer than the average period
for which such property is used by customers. Id.
Section 1.469-1T(e)(3)(v), Temporary Income Tax Regs., 53
Fed. Reg. 5702 (Feb. 25, 1988), defines extraordinary personal
services as follows:
For purposes of paragraph (e)(3)(ii)(C) of this
section, extraordinary personal services are provided
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011