The U.S. Internal Revenue Service thinks major engine overhauls are capital expenditures rather than expenses, and tax attorneys agree that even though it only represents IRS's opinion in a single case, the theory could easily be applied broadly throughout the industry with multi-million- dollar effects. The little-noticed May 3 Technical Advice Memorandum is not a formal ruling, so it does not carry the force of law. In fact, a stamp on the document says it "may not be used or ...


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