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method of identifying an aircraft/airframe is by its "tail number". You should
request that where possible the tail number be used to identify aircraft. As the
"tail number" is commonly used by taxpayers to identify their aircraft, this
should generally not be a problem. In the event the tail number cannot be
provided, the taxpayer will use an alternate identifier. In this case,
reconciliation between the tail number and the alternate identifier should be
requested. If there are few or no third or later HMV’s, the costs involved are
in line with the cost of a situation 1 or 2 HMV; the Team Manager should
consider eliminating this area from the audit plan.
2. If the audit of the HMV is necessary, contact the Air Transport Technical
Advisor for his/her support and assistance. The effective examination of the
HMV issue requires an understanding of the taxpayer’s accounting and
maintenance practices. If you have not already done so, request the taxpayer
provide a copy of its capitalization policy with regard to aircraft modifications
and/or upgrades.
3. If you have not held a meeting with the taxpayer’s employees who are
responsible for airframe HMV, do so. The purpose of this meeting is to
develop an understanding of the taxpayer’s maintenance practices, how
maintenance is accounted for, and the terminology used within the company
to describe it.
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Based on the data collected, the Team Manager should determine the
extent of resources to devote to this issue. Conversations with the
taxpayer and the Air Transport team may assist you in setting the scope
and depth and help minimize audit burden on both the taxpayer and the
audit team.
Conduct of the Examination
1. By now, the Team Manager should have secured needed engineering support
and determined which airframes to examine. The focus of the sample should
be on aircraft where the HMV is likely to have a capital component (i.e. fall
within the ruling’s situation 3, aircraft converted to another use, costs
exceeding the norm, or used aircraft purchased and rehabilitated).
2. Following the selection of an HMV to examine, and if you have not already
done so, request a tour of the taxpayer’s maintenance facility. The purpose of
this tour is for you to further develop your understanding of the taxpayer’s
maintenance practices. If the taxpayer uses an outside third party to perform
its maintenance, the time of the visit should ideally be set to take place when
one of the taxpayer’s aircraft is undergoing an HMV.
3. Request the information the taxpayer relied on in determining the useful life
of its aircraft. Such information could include, but is not limited to,
information on acquisition dates, age at time of acquisition, maintenance
status when acquired, historic data on how long aircraft are retained, and
current age of the taxpayer’s fleet. The taxpayer’s records should be regarded
as the preferred source of this information since they reflect the taxpayer’s
unique operating environment. This data should be compared to that secured
from the Air Transport team to identify any significant variances needing
reconciliation.
4. Request a complete copy of the taxpayer’s maintenance plan (may also be
called a maintenance manual or a maintenance planning document) as filed
with the FAA for the years under examination for each fleet type in the sample.
A maintenance plan is a "living document" and changes with time so it is
important that you have documents that reflect the work that was actually done
on the airframe. If the taxpayer has only the current document, you should
work with the taxpayer on a reconstruction. It may be that a reconstruction is
unnecessary because the taxpayer believes that the current document does not
differ in any significant regard from the document in use during the years
under audit. If this is so, the execution of a document to this effect is
suggested to prevent any misunderstandings in the future.
5. Request the applicable "workscope" or "statement of work" documents for
each aircraft in the sample. If the same workscope was used for several of the
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aircraft in the sample, only one set of the documents needs to be supplied,
provided the taxpayer identifies all aircraft to which the documents apply.
6. If the taxpayer uses a third party maintenance vendor to perform work on any
of the sample aircraft, request a complete copy of the taxpayer’s contract with
the vendor along with copies of the invoices for each sample aircraft. If the
taxpayer performs its HMV in-house, request relevant maintenance records.
　
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