rp-07-48.pdf

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Part III

Administrative, Procedural, and Miscellaneous

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 (8
th
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

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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 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.

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.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 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

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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.
.08 Section 446(e) and § 1.446-1(e)(2)(i) state that, except as otherwise

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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);

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(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 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

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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
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

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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

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acquisition date of the rotable spare part for purposes of the acquisition date
requirement in § 168(k), 1400L(b), or 1400N(d).
.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

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rotable spare parts. Any method other than one provided in this section 4.05
(including the Anet 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
disposed 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;

11
(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

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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 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 to Change a Method of Accounting, 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.

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(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:
(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

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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 the methodology used to determine the

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§ 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.

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(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 § 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

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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. [enter
page number of IRB] for making a change in method of accounting from
inventory property to depreciable property for rotable spare parts);
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

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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.
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.
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

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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).