Ezel / IRS Rulings / 201013045

CCA 201013045: IRS distinguishes units of property used for depreciation and retirement

Number
201013045
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Retirements
Topics
Income and deductions
Code sections
§ 168, § 6110
Ruling dated
March 2, 2010
Publicly released
April 2, 2010
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2010, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2010
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advice addressed whether the asset, or unit of property, used for depreciation and retirement purposes must be the same as the unit of property used for repair and capitalization purposes. The advice stated that these units of property may differ. The point matters because the relevant unit can affect how an expense or retirement is analyzed for federal tax purposes.

Ruling snapshot

  • Question: Must the unit of property be the same for depreciation, retirement, repair, and capitalization purposes?
  • Outcome: Advice given
  • Key authorities: IRC § 168

Full text (IRS public release)

ID: CCA_2010030208313457 Number: 201013045
Release Date: 4/2/2010
Office: ------------
UILC: 168.35-00

From: ------------------
Sent: Tuesday, March 02, 2010 8:31:44 AM
To: ----------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------------------
------------------------------------
Subject: RE: Additional CAM Needed?

---------I would also like to add that what is the asset (UOP) for depreciation
and retirement purposes may not be the same as the UOP for repair/capitalization
purposes.

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