oelow, we respectfully request that the Internal Revenue Service ("Service')
review the treatment in TAM200945037' of leasing aircraft to 5-percent owners and related parties under
the depreciation limitation ... rather than in the
concuct of a trade or bLsiness: 7
As explained in TAM200945037, ItIhe exceptions under section 280F(d)(6)(C) were des geed to frevent ... Deficit reduction Act of 1984, P.L. 98-369,
Pages 559-560; sea also TAM200945037 (Nov. 6, 2009).
" TAM200945037
EFTA00602758
taxanalvsts'
DOCUMENT S RVICE
Doc 2013.19374 (7 pgs)
National