Rev. Proc. 2007-48 Rotable Spare Parts Safe Harbor Method

SECTION 9. DRAFTING
INFORMATION
The principal authors of this revenue procedure are Vicky Tsilas and
Johanna Som de Cerff of the Office of
Associate Chief Counsel (Financial Institutions & Products). For further information regarding this revenue procedure,
contact Johanna Som de Cerff at (202)
622–3980 (not a toll-free call).

26 CFR 601.204: Changes in accounting periods
and in methods of accounting.
(Also Part I, §§ 167, 168, 446, 481; 1.446–1,
1.481–1.)

Rev. Proc. 2007–48
SECTION 1. PURPOSE
This revenue procedure provides a
safe harbor method of accounting to treat
rotable spare parts as depreciable assets
in accordance with Rev. Rul. 2003–37,
2003–1 C.B. 717, and provides procedures for taxpayers to obtain the automatic
consent of the Commissioner of Internal Revenue to change to the safe harbor
method of accounting.
SECTION 2. BACKGROUND
.01 In both Hewlett-Packard Co.. v.
United States, 71 F.3d 398 (Fed. Cir.
1995), rev’g Apollo Computer, Inc. v.
United States, 32 Fed. Cl. 334 (1994),
and Honeywell, Inc. v. Commissioner,
T.C. Memo. 1992–453, aff’d per curiam,
27 F.3d 571 (8th Cir. 1994), the courts
held that the taxpayers properly treated
their pools of rotable spare parts as depreciable assets, rather than as inventory.
The taxpayers in Hewlett-Packard and
Honeywell were engaged in the trade or
business of manufacturing computers and
computer parts, and also in the business
of repairing and servicing computers purchased or leased by their customers. Most
of the taxpayers’ computer maintenance
operations were conducted pursuant to
standardized maintenance agreements that
obligated the taxpayers to provide all parts
and labor, product upgrades, preventive
maintenance, and telephone assistance
necessary to keep a customer’s computer

2007–29 I.R.B.

operational for the duration of the contract (usually one year) in exchange for
a predetermined fee. In conducting their
computer maintenance operations, the
taxpayers sent repair technicians to a customer’s location to diagnose and repair
the customer’s computer. The taxpayers’
repair technicians used a supply of rotable
spare parts to diagnose problems in a
customer’s equipment, and then would
exchange a working part for any malfunctioning part. The malfunctioning part
removed from the customer’s equipment
would then be repaired and placed in the
taxpayers’ rotable spare parts pools for
continued use in the maintenance operation. The taxpayers followed this practice
of exchanging their rotable spare parts
for malfunctioning parts in a customer’s
computer to avoid rendering a customer’s
computer inoperative while the original
part was being repaired.
The parts in the taxpayers’ rotable
spare parts pools were obtained from
the taxpayers’ manufacturing facilities.
However, the taxpayers operated their
computer maintenance operations separate from their manufacturing operations
and at all times the rotable spare parts were
physically segregated from the taxpayers’
regular manufacturing inventories.
.02 In Rev. Rul. 2003–37, the Internal Revenue Service announced that it will
follow the judgments in Hewlett-Packard
and Honeywell, and that a taxpayer may
treat rotable spare parts as depreciable assets, provided the taxpayer’s facts are substantially similar to the facts in those cases.
.03 The Service and Department of the
Treasury are aware that the treatment of
rotable spare parts as depreciable assets
has continued to be the subject of controversy in situations when a taxpayer, as part
of its maintenance operations, sells rotable
spare parts from the taxpayer’s pool of
rotable spare parts that are treated as depreciable assets. For reasons of administrative convenience, and to reduce further controversy, if a taxpayer within the
scope of this revenue procedure maintains
one or more pools of rotable spare parts
that it treats as depreciable assets and sells
rotable spare parts from these pools, the
Service will not challenge the taxpayer’s
treatment of the pools of rotable spare parts
as depreciable assets for a particular taxable year if, for that year, the taxpayer uses

110

the method of accounting provided in section 4 of this revenue procedure.
.04 Section 167(a) of the Internal Revenue Code provides a depreciation allowance for the exhaustion, wear and
tear, and obsolescence of property used
in a trade or business. The depreciation
deduction provided by § 167(a) for tangible property placed in service after 1986
generally is determined under § 168. Depreciation allowances under § 168 are
determined using either: (1) the general
depreciation system (GDS) in § 168(a);
or (2) the alternative depreciation system
(ADS) in § 168(g). Under either depreciation system, the depreciation deduction
is computed by using a prescribed depreciation method, recovery period, and
convention. For purposes of either GDS
or ADS, the applicable recovery period is
determined by reference to class life or by
statute.
.05 Rev. Proc. 87–56, 1987–2 C.B.
674, as clarified and modified by Rev.
Proc. 88–22, 1988–1 C.B. 785, sets forth
the class lives of depreciable tangible
property that are necessary to determine
the recovery period of that property under
§ 168. The revenue procedure establishes
two broad categories of depreciable assets:
(1) asset classes 00.11 through 00.4 that
consist of specific assets used in all business activities; and (2) asset classes 01.1
through 80.0 that consist of assets used in
specific business activities.
.06 Pursuant to § 167(c), the basis on
which exhaustion, wear and tear, and obsolescence are to be allowed in respect
of any property generally is the adjusted
basis provided in § 1011 for the purpose
of determining the gain on the sale or
other disposition of such property. See
also § 1.168(b)–1(a)(3) and (a)(4) of the
Income Tax Regulations for the definitions of unadjusted depreciable basis and
adjusted depreciable basis, respectively,
for purposes of § 168.
.07 Under § 446(b), the Commissioner
has broad authority to determine whether
a method of accounting clearly reflects income. Section 1.446–1(c)(2)(ii) provides
that the Commissioner may authorize a
taxpayer to adopt or change to a permissible method of accounting although the
method is not specifically permitted if,
in the opinion of the Commissioner, that
method clearly reflects income.

July 16, 2007

.08 Section 446(e) and § 1.446–
1(e)(2)(i) state that, except as otherwise
provided, a taxpayer must secure the consent of the Commissioner before changing
a method of accounting for federal income
tax purposes. Section 1.446–1(e)(3)(ii)
authorizes the Commissioner to prescribe
administrative procedures setting forth the
limitations, terms, and conditions necessary to obtain the Commissioner’s consent
to effect the change in method of accounting and to prevent amounts from being
duplicated or omitted. The terms and conditions the Commissioner may prescribe
include the year of change, whether the
change is to be made with a § 481(a)
adjustment or on a cut-off basis, and the
§ 481(a) adjustment period.
.09 Rev. Proc. 2002–9, 2002–1 C.B.
327 (as modified and amplified by Rev.
Proc. 2002–19, 2002–1 C.B. 696, modified and clarified by Announcement
2002–17, 2002–1 C.B. 561, and amplified, clarified, and modified by Rev. Proc.
2002–54, 2002–2 C.B. 432), provides procedures by which a taxpayer may obtain
automatic consent to change to a method
of accounting described in the Appendix
of Rev. Proc. 2002–9.
.10 Section 481(a) requires adjustments necessary to prevent amounts from
being duplicated or omitted by reason of a
change in method of accounting.
SECTION 3. SCOPE
This revenue procedure applies to a taxpayer that —
(1) repairs customer-owned (or customer-leased) equipment under warranty
or maintenance agreements that are provided to the customer for either no charge
or a predetermined fee that does not
change during the term of the agreement
(regardless of the taxpayer’s costs to comply with the agreement);
(2) is obligated under the warranty or
maintenance agreements to repair the customer’s equipment (including all parts and
labor related to the repair) for either no
charge or a nominal service fee that is unrelated to the actual cost of parts and labor
provided;
(3) maintains a pool or pools of spare
parts that are used primarily in the taxpayer’s maintenance operation of repairing customer-owned (or customer-leased)
equipment under warranty or maintenance

July 16, 2007

agreements, exchanges the spare parts for
defective parts in the customer-owned (or
customer-leased) equipment, and generally repairs and reuses the defective parts
in its pool of spare parts (the “rotable spare
parts”); and
(4) has a depreciable interest in the
rotable spare parts and has placed in service the rotable spare parts after 1986.
SECTION 4. SAFE HARBOR METHOD
OF ACCOUNTING FOR ROTABLE
SPARE PARTS
.01 In General. This section 4 describes
a safe harbor method of accounting for
rotable spare parts. A taxpayer is eligible
to use the safe harbor method of accounting in any taxable year in which the taxpayer —
(a) is within the scope of section 3 of
this revenue procedure; and
(b) has gross sales (less returns) of
rotable spare parts from the taxpayer’s
maintenance operation that do not exceed
10 percent of the taxpayer’s total gross
revenues (less returns) from its maintenance operation for the taxable year.
.02 Description of Safe Harbor Method
of Accounting. A taxpayer using the safe
harbor method of accounting for rotable
spare parts must —
(1) capitalize the cost of the rotable
spare parts under § 263(a) and depreciate
these parts under § 168 in accordance with
section 4.03 of this revenue procedure;
(2) establish one or more pools for the
rotable spare parts in accordance with section 4.04 of this revenue procedure;
(3) identify the disposed rotable spare
parts in accordance with section 4.05 of
this revenue procedure; and
(4) determine the depreciable basis of
the rotable spare parts for depreciation purposes in accordance with § 167(c), § 1011,
and § 1.168(b)–1(a)(3) and (a)(4).
.03 Depreciation Allowable.
(1) In general. For purposes of determining the depreciation allowable for the
rotable spare parts under the safe harbor
method of accounting described in section
4.02 of this revenue procedure, the applicable depreciation method for the rotable
spare parts is determined under § 168(b)(1)
or (2), as applicable, unless either (a) the
taxpayer made a timely valid election under § 168(b)(5) to use the straight line
method of depreciation for the class of

111

property (as set forth in § 168(e)) in which
the rotable spare parts are included, or
(b) the rotable spare parts are required to
be depreciated under the alternative depreciation system in § 168(g). Rotable
spare parts required to be depreciated under the alternative depreciation system include rotable spare parts in a class of property (as set forth in § 168(e)) for which the
taxpayer made a timely valid election under § 168(g)(7). In addition, the applicable
recovery period for the rotable spare parts
is determined under § 168(c) or 168(g), as
applicable, by including the rotable spare
parts in the following asset class of Rev.
Proc. 87–56:
(a) the asset class in Rev. Proc.
87–56 applicable to the taxpayer’s manufacturing activity if the taxpayer, under
warranty or maintenance agreements,
repairs only customer-owned (or customer-leased) equipment that is manufactured only by the taxpayer; or
(b) asset class 57.0, Distributive
Trades or Services, if: (i) the taxpayer, under warranty or maintenance agreements,
repairs both customer-owned (or customer-leased) equipment that is manufactured by the taxpayer and customer-owned
(or customer-leased) equipment that is
manufactured by others; (ii) the taxpayer
is not a manufacturer of the type of customer-owned (or customer-leased) equipment that is being repaired; or (iii) the
taxpayer (including a taxpayer described
in section 4.03(1)(a) of this revenue procedure) charges the customer a nominal
service fee (that is unrelated to the actual
cost of parts and labor provided) to repair customer-owned (or customer-leased)
equipment under warranty or maintenance
agreements.
(2) Additional first year depreciation
deduction. In determining the amount of
the § 481(a) adjustment as described in
section 5.04 of this revenue procedure, the
additional first year depreciation deduction allowable under § 168(k), 1400L(b),
or 1400N(d) is taken into account for
any qualifying rotable spare part. However, the deemed placed-in-service date
referred to in section 5.04(2)(b) of this revenue procedure for the rotable spare part
is not the acquisition date of the rotable
spare part for purposes of the acquisition
date requirement in § 168(k), 1400L(b),
or 1400N(d).

2007–29 I.R.B.

.04 Establishment of Pools.
(1) In general. Under the safe harbor
method of accounting described in section
4.02 of this revenue procedure, a taxpayer
must establish one or more pools for the
rotable spare parts. Each pool must include only the rotable spare parts that are
placed in service by the taxpayer in the
same taxable year and have the same: (a)
asset class under Rev. Proc. 87–56, (b)
applicable depreciation method, (c) applicable recovery period, and (d) applicable
convention. Additionally, rotable spare
parts subject to the mid-quarter convention may only be grouped into a pool with
rotable spare parts that are placed in service in the same quarter of the taxable year.
(2) General asset account election. If
a taxpayer within the scope of this revenue procedure is changing the treatment
of its rotable spare parts to the safe harbor
method of accounting described in section
4.02 of this revenue procedure, the taxpayer also may elect to establish general
asset accounts for the rotable spare parts
beginning in the year of change, provided
the terms and conditions in section 5.02(5)
of this revenue procedure are satisfied beginning in the year of change.
.05 Dispositions.
(1) In general. Under the safe harbor
method of accounting described in section
4.02 of this revenue procedure, a taxpayer
must use a method of accounting provided
in this section 4.05 for identifying the disposed rotable spare parts. Any method
other than one provided in this section 4.05
(including the “net additions” method) is
not a permissible method of accounting for
dispositions.
(2) Permissible methods of identifying
disposed rotable spare parts. For purposes
of the safe harbor method of accounting
described in section 4.02 of this revenue
procedure, a taxpayer must use one of the
following methods of accounting to identify its disposed rotable spare parts:
(a) Specific identification of each
disposed rotable spare part; or
(b) A first-in, first-out method of
accounting if, in the case of rotable spare
parts that are mass assets, the total rotable
spare parts dispositions during a particular
taxable year are readily determined from
a taxpayer’s records but it is impracticable for the taxpayer to maintain records
from which the taxpayer can determine the
particular taxable year in which the dis-

2007–29 I.R.B.

posed rotable spare parts were placed in
service by the taxpayer. A taxpayer using
the first-in, first-out method of accounting
under this section 4.05(2)(b) must identify
the rotable spare parts disposed of in a taxable year from the pool with the earliest
placed-in-service year existing at the beginning of the taxable year of the disposition. For purposes of this paragraph, mass
assets are a mass or group of individual
items of depreciable property —
(i) that are not necessarily
homogeneous;
(ii) each of which is minor in
value relative to the total value of the mass
or group;
(iii) numerous in quantity;
(iv) usually accounted for
only on a total dollar or quantity basis;
(v) with respect to which separate identification is impracticable; and,
(vi) that are placed in service
by the taxpayer in the same taxable year.
SECTION 5. CHANGES IN METHOD
OF ACCOUNTING
.01 In General. Any change in a taxpayer’s treatment of rotable spare parts
pursuant to this revenue procedure is a
change in method of accounting to which
§ 446 and (except as otherwise provided in
this section 5) § 481, and the regulations
thereunder, apply. This section 5 applies
to a taxpayer within the scope of this revenue procedure that —
(1) currently does not capitalize and
depreciate the cost of its rotable spare parts
and wants to change to the safe harbor
method of accounting described in section
4.02 of this revenue procedure;
(2) currently treats its rotable spare
parts in accordance with sections 4.02(1),
(3), and (4) of this revenue procedure and
wants to establish rotable spare parts pools
in accordance with section 4.04(1) of this
revenue procedure;
(3) currently treats its rotable spare
parts in accordance with sections 4.02(1),
(2), and (4) of this revenue procedure and
wants to change to a method of accounting described in section 4.05(2) of this
revenue procedure for identifying the disposed rotable spare parts; or
(4) currently treats its rotable spare
parts in accordance with sections 4.02(1)
and (4) of this revenue procedure and
wants to establish rotable spare parts pools

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in accordance with section 4.04(1) of this
revenue procedure and change to a method
of accounting described in section 4.05(2)
of this revenue procedure for identifying
the disposed rotable spare parts.
.02 Automatic Change. A taxpayer
within the scope of this revenue procedure
is granted the consent of the Commissioner to make a change in method of
accounting described in section 5.01 of
this revenue procedure provided that the
taxpayer follows the automatic change in
method of accounting provisions in Rev.
Proc. 2002–9 (or any successor), with the
following modifications:
(1) The scope limitations in section
4.02 of Rev. Proc. 2002–9 do not apply to
a taxpayer that wants to make the change
in method of accounting for its first or
second taxable year ending on or after
December 31, 2006, provided the taxpayer’s method of accounting for rotable
spare parts is not an issue under consideration for taxable years under examination,
within the meaning of section 3.09 of Rev.
Proc. 2002–9, at the time the Form 3115,
Application for Change in Accounting
Method, is filed with the national office.
(2) For purposes of completing line 1a
of Form 3115, the designated automatic
accounting method change number for the
changes in method of accounting provided
in section 5.01 of this revenue procedure is
No. 109.
(3) The taxpayer must compute any
applicable § 481(a) adjustment in accordance with section 5.04 of this revenue
procedure.
(4) The taxpayer must own the rotable
spare parts as of the beginning of the year
of change and must determine the adjusted
depreciable basis of the rotable spare parts
as of the beginning of the year of change in
accordance with § 167(c), § 1011(a), and
§ 1.168(b)–1(a)(3) and (a)(4). The reductions required by § 1016(a)(2) for the depreciation allowable for the rotable spare
parts must be determined under the method
of accounting for depreciation allowable
under section 4.03 of this revenue procedure for all open and closed taxable years
prior to the year of change.
(5) If a taxpayer described in section
4.04(2) of this revenue procedure elects
to establish general asset accounts for the
rotable spare parts, the taxpayer must meet
all of the following requirements beginning in the year of change:

July 16, 2007

(a) The taxpayer must consent
to, and agree to apply, all of the provisions of § 1.168(i)–1 to the rotable spare
parts included in the general asset accounts, beginning with the year of change.
Thus, pursuant to § 1.168(i)–1(k)(1), the
establishment of general asset accounts
beginning with the year of change is irrevocable and will be binding on the
taxpayer for computing taxable income
for the year of change and for all subsequent taxable years, except as provided
in § 1.168(i)–1(c)(1)(ii)(A), (e)(3), (g), or
(h)(1).
(b) The taxpayer must use a
method of accounting described in section 4.05(2) of this revenue procedure for
identifying the disposed rotable spare parts
for purposes of applying § 1.168(i)–1(i).
(c) The taxpayer must group the
rotable spare parts into one or more general
asset accounts in accordance with the rules
in § 1.168(i)–1(c) and each general asset
account must include a beginning balance
for both the unadjusted depreciable basis
and the depreciation reserve of the general
asset account. The beginning balance for
the unadjusted depreciable basis of each
general asset account is equal to the sum
of the unadjusted depreciable bases as of
the beginning of the year of change for all
rotable spare parts included in that general
asset account. The beginning balance of
the depreciation reserve of each general asset account is equal to the portion of the accumulated depreciation component of the
net § 481(a) adjustment that is allocable to
the rotable spare parts included in that general asset account.
.03 Changes Made on a Cut-off Method.
A taxpayer making a change in method of
accounting described in section 5.01(2),
(3), or (4) of this revenue procedure must
make the change on a cut-off method.
Thus, the new method of accounting
applies to rotable spare parts placed in
service, or disposed of, by the taxpayer
beginning in the year of change.
.04 Changes Made Using a § 481(a)
Adjustment.
(1) In general. A taxpayer making
a change in method of accounting under
section 5.01(1) of this revenue procedure
to the safe harbor method of accounting
must make the change using a § 481(a)
adjustment. As required by the Form
3115, the taxpayer must attach a summary
of the computation and an explanation of

July 16, 2007

the methodology used to determine the
§ 481(a) adjustment. To use the safe harbor method of accounting, the taxpayer
also must include in the required attachment the amount of the taxpayer’s total
gross sales (less returns) of rotable spare
parts and gross revenues (less returns)
from the taxpayer’s maintenance operation for the year of change and every year
of the qualifying period used to compute
the § 481(a) adjustment.
(2) Computation of § 481(a) Adjustment.
(a) In computing the § 481(a)
adjustment, the taxpayer must use the
adjusted depreciable basis of the rotable
spare parts computed under the safe harbor method, as of the first day of the
year of change taking into account the
placed-in-service date provided for in subparagraph (2)(b) of this section 5.04 and
the qualifying period described in subparagraph (3) of this section 5.04.
(b) Any rotable spare parts that
were: (i) placed in service by the taxpayer
after 1986 and in a taxable year prior to the
earliest taxable year of the qualifying period, and (ii) owned by the taxpayer as of
the beginning of the earliest taxable year
of the qualifying period, must be treated
as placed in service by the taxpayer in the
earliest taxable year of the qualifying period. A taxpayer that does not have the
books and records to determine whether
it meets the requirements of section 4.01
of this revenue procedure in every year in
which the rotable spare parts on hand as of
the beginning of the year of change were
placed in service and in every subsequent
year prior to the year of change, must compute the § 481(a) adjustment using a qualifying period that can be established based
on its books and records.
(3) Qualifying period. For purposes
of this section 5.04, a “qualifying period”
consists of the taxable year, or consecutive
taxable years, immediately preceding the
year of change during which the taxpayer
can establish that it meets the requirements
of section 4.01 of this revenue procedure.
.05 Nonautomatic Changes. If a taxpayer is not eligible to change to the safe
harbor method of accounting provided in
this revenue procedure, the taxpayer may
request to change its method of accounting for treating rotable spare parts by filing a Form 3115 with the Commissioner
in accordance with the requirements of

113

§ 1.446–1(e)(3)(i) and Rev. Proc. 97–27,
1997–1 C.B. 680 (as modified and amplified by Rev. Proc. 2002–19, 2002–1 C.B.
696, and amplified and clarified by Rev.
Proc. 2002–54, 2002–2 C.B. 432).
.06 Requirement to Change From the
Safe Harbor Method. A taxpayer that
changes to the safe harbor method under this revenue procedure and subsequently fails to meet the requirements of
section 4.01 of this revenue procedure
must change its method of accounting
for rotable spare parts to an appropriate inventory method of accounting for
the first taxable year in which the taxpayer becomes ineligible to use the safe
harbor method of accounting for rotable
spare parts. A taxpayer that is required
to change its method of accounting under
this section 5.06 must file a Form 3115 in
accordance with the automatic change in
method of accounting provisions of Rev.
Proc. 2002–9 (or any successor), with the
following modifications:
(1) the scope limitations in section
4.02 of Rev. Proc. 2002–9 do not apply;
and
(2) the designated automatic accounting method change number for changes in
method of accounting from the safe harbor method of accounting made pursuant
to this section 5.06 is No. 110.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
.01 Rev. Proc. 2002–9 is modified
and amplified to include the accounting
method changes described in this revenue
procedure in section 3 of the APPENDIX.
.02 Section 2.01(1)(d)(xiii)(A) of the
APPENDIX of Rev. Proc. 2002–9 (as
modified by Rev. Proc. 2004–11, 2004–1
C.B. 311) is modified to read as follows:
(A) a change in inventory costs (for
example, when property is reclassified
from inventory property to depreciable
property, or vice versa) (but see section
3.02 of this APPENDIX for making a
change in method of accounting from inventory property to depreciable property
for unrecoverable line pack gas or unrecoverable cushion gas, and Rev. Proc.
2007–48, 2007–29 I.R.B. 110, for making
a change in method of accounting from
inventory property to depreciable property
for rotable spare parts);

2007–29 I.R.B.

SECTION 7. EFFECTIVE DATE
This revenue procedure is effective for
taxable years ending on or after December
31, 2006. The Service will not challenge
a taxpayer’s use of the safe harbor method
of accounting described in section 4.02 of
this revenue procedure in an earlier taxable year if the taxpayer, for that taxable
year, meets the requirements of section
4.01 of this revenue procedure. Moreover,
if a taxpayer currently uses the safe harbor
method of accounting described in section
4.02 of this revenue procedure and the use
of such method is an issue under consideration (within the meaning of section 3.09
of Rev. Proc. 2002–9) in examination, before an appeals office, or before the U.S.
Tax Court and the taxpayer meets the requirements of section 4.01 of this revenue
procedure for the taxable years under examination, before an appeals office, or before the U.S. Tax Court, the issue will not
be further pursued.

2007–29 I.R.B.

SECTION 8. PAPERWORK
REDUCTION ACT
The collection of information contained in this revenue procedure has been
reviewed and approved by the Office
of Management and Budget in accordance with the Paperwork Reduction Act
(44 U.S.C. 3507) under control number
1545–2070. An agency may not conduct
or sponsor, and a person is not required to
respond to, a collection of information unless the collection of information displays
a valid OMB control number.
The collection of information in this
revenue procedure is in section 5.04(1).
This information is required to determine
whether the taxpayer qualifies to use the
safe harbor method of accounting. The
collection of information is required to
obtain a benefit. The likely respondents
are business or other for-profit institutions. The estimated total annual reporting
and/or recordkeeping burden is 75 hours.
The estimated annual frequency of responses is 300.

114

Books or records relating to a collection
of information must be retained as long as
their contents may become material in the
administration of any internal revenue law.
Generally, tax returns and tax information
are confidential, as required by 26 U.S.C.
6103.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Gwen Turner of the Office
of Associate Chief Counsel (Income Tax
and Accounting). For further information
regarding this revenue procedure, contact Ms. Turner at (202) 622–5020 (not
a toll-free call). For further information
regarding the method of computing depreciation for rotable spare parts, the establishment of pools or general asset accounts
for rotable spare parts, or the method of
identifying the disposed rotable spare
parts, contact Douglas Kim of the Office
of Associate Chief Counsel (Income Tax
and Accounting) at (202) 622–4930 (not a
toll-free call).

July 16, 2007