Rev. Proc. 2007-30

Rev. Proc. 2007-30

Rev. Proc. 2007-30

SECTION 1. PURPOSE

01. This revenue procedure provides: (1) limitations on depreciation deductions for owners of passenger automobiles first placed in service by the taxpayer during calendar year 2007, including a separate table of limitations on depreciation deductions for trucks and vans; and (2) the amounts to be included in income by lessees of passenger automobiles first leased by the taxpayer during calendar year 2007, including a separate table of inclusion amounts for lessees of trucks and vans.

02. The tables detailing these depreciation limitations and lessee inclusion amounts reflect the automobile price inflation adjustments required by § 280F(d)(7).

03. Section 280F(a)(1)(C), which directed the use of higher depreciation deduction limits for certain electric automobiles, was applicable only to property placed in service after December 31, 2001 and before January 1, 2007. Accordingly, separate tables are no longer provided for electric automobiles, and taxpayers should use the applicable table provided in this revenue procedure.

SECTION 2. BACKGROUND

01. For owners of passenger automobiles, § 280F(a) imposes dollar limitations on the depreciation deduction for the year that the passenger automobile is placed in service by the taxpayer and each succeeding year. Section 280F(d)(7) requires the amounts allowable as depreciation deductions to be increased by a price inflation adjustment amount for passenger automobiles placed in service after 1988. The method of calculating this price inflation amount for trucks and vans placed in service in or after calendar year 2003 uses a different CPI “automobile component” (the “new trucks” component) than that used in the price inflation amount calculation for other passenger automobiles (the “new cars” component), resulting in somewhat higher depreciation deductions for trucks and vans. This change reflects the higher rate of price inflation that trucks and vans have been subject to since 1988. For purposes of this revenue procedure, the term “trucks and vans” refers to passenger automobiles that are built on a truck chassis, including minivans and sport utility vehicles (SUVs) that are built on a truck chassis.

02. For leased passenger automobiles, § 280F(c) requires a reduction in the deduction allowed to the lessee of the passenger automobile. The reduction must be substantially equivalent to the limitations on the depreciation deductions imposed on owners of passenger automobiles. Under § 1.280F-7(a), this reduction requires the lessees to include in gross income an inclusion amount determined by applying a formula to the amount obtained from a table. There is a table for lessees of trucks and vans and a table for all other passenger automobiles. Each table shows inclusion amounts for a range of fair market values for each tax year after the passenger automobile is first leased.

SECTION 3. SCOPE

01. The limitations on depreciation deductions in section 4.02(2) of this revenue procedure apply to passenger automobiles (other than leased passenger automobiles) that are placed in service by the taxpayer in calendar year 2007, and continue to apply for each tax year that the passenger automobile remains in service.

02. The tables in section 4.03 of this revenue procedure apply to leased passenger automobiles for which the lease term begins during calendar year 2007. Lessees of such passenger automobiles must use these tables to determine the inclusion amount for each tax year during which the passenger automobile is leased. See Rev. Proc. 2002-14, 2002-1 C.B. 450, for passenger automobiles first leased before January 1, 2003, Rev. Proc. 2003-75, 2003-2 C.B. 1018, for passenger automobiles first leased during calendar year 2003, Rev. Proc. 2004-20, 2004-1 C.B. 642, for passenger automobiles first leased during calendar year 2004, Rev. Proc. 2005-13, 2005-1 C.B. 759, for passenger automobiles first leased during calendar year 2005, and Rev. Proc. 2006-18, 2006-1 C.B. 645, for passenger automobiles first leased during calendar year 2006.

SECTION 4. APPLICATION

01. In General.

(1) Limitations on Depreciation Deductions for Certain Automobiles. The limitations on depreciation deductions for passenger automobiles placed in service by the taxpayer for the first time during calendar year 2007 are found in Tables 1 and 2 in section 4.02(2) of this revenue procedure. Table 1 of this revenue procedure provides limitations on depreciation deductions for a passenger automobile (other than a truck or van). Table 2 of this revenue procedure provides limitations on depreciation deductions for a truck or van.

(2) Inclusions in Income of Lessees of Passenger Automobiles. A taxpayer first leasing a passenger automobile during calendar year 2007 must determine the inclusion amount that is added to gross income using the tables in section 4.03 of this revenue procedure. The inclusion amount is determined using Table 3 in the case of a passenger automobile (other than a truck or van), and Table 4 in the case of a truck or van. In addition, the procedures of § 1.280F-7(a) must be followed.

02. Limitations on Depreciation Deductions for Certain Automobiles.

(1) Amount of the Inflation Adjustment. Under § 280F(d)(7)(B)(i), the automobile price inflation adjustment for any calendar year is the percentage (if any) by which the CPI automobile component for October of the preceding calendar year exceeds the CPI automobile component for October 1987. The term “CPI automobile component” is defined in § 280F(d)(7)(B)(ii) as the “automobile component” of the Consumer Price Index for all Urban Consumers published by the Department of Labor (the CPI). The new car component of the CPI was 115.2 for October 1987 and 136.3 for October 2006. The October 2006 index exceeded the October 1987 index by 21.1. The Service has, therefore, determined that the automobile price inflation adjustment for 2007 for passenger automobiles (other than trucks and vans) is 18.32 percent (21.1/115.2 x 100%). This adjustment is applicable to all passenger automobiles (other than trucks and vans) that are first placed in service in calendar year 2007. The dollar limitations in § 280F(a) must therefore be multiplied by a factor of 0.1832, and the resulting increases, after rounding to the nearest $100, are added to the 1988 limitations to give the depreciation limitations applicable to passenger automobiles (other than trucks and vans) for calendar year 2007. To determine the dollar limitations applicable to trucks and vans first placed in service during calendar year 2007, the new truck component of the CPI is used instead of the new car component. The new truck component of the CPI was 112.4 for October 1987 and 141.4 for October 2006. The October 2006 index exceeded the October 1987 index by 29.0. The Service has, therefore, determined that the automobile price inflation adjustment for 2007 for trucks and vans is 25.80 percent (29.0/112.4 x 100%). This adjustment is applicable to all trucks and vans that are first placed in service in calendar year 2007. The dollar limitations in § 280F(a) must therefore be multiplied by a factor of 0.2580, and the resulting increases, after rounding to the nearest $100, are added to the 1988 limitations to give the depreciation limitations applicable to trucks and vans.

(2) Amount of the Limitation. For passenger automobiles placed in service by the taxpayer in calendar year 2007, Tables 1 and 2 contain the dollar amount of the depreciation limitation for each tax year. Use Table 1 for passenger automobiles placed in service by the taxpayer in calendar year 2007. Use Table 2 for trucks and vans placed in service by the taxpayer in calendar year 2007.

REV. PROC. 2007-30 TABLE 1
DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2007
------
Tax YearAmount
------
1st Tax Year$3,060
2nd Tax Year$4,900
3rd Tax Year$2,850
Each Succeeding Year$1,775
REV. PROC. 2007-30 TABLE 2
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2007
------
Tax YearAmount
------
1st Tax Year$3,260
2nd Tax Year$5,200
3rd Tax Year$3,050
Each Succeeding Year$1,875

03. Inclusions in Income of Lessees of Passenger Automobiles.

The inclusion amounts for passenger automobiles first leased in calendar year 2007 are calculated under the procedures described in § 1.280F-7(a). Lessees of passenger automobiles other than trucks and vans should use Table 3 of this revenue procedure in applying these procedures, while lessees of trucks and vans should use Table 4 of this revenue procedure.

REV. PROC. 2007-30 TABLE 3
DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES (THAT ARE NOT TRUCKS OR VANS) WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2007
---------------------
Fair Market Value of Passenger AutomobileTax Year During Lease
---------------------
OverNot Over1st2nd3rd4th5th & later
---------------------
$15,500$15,80025111113
15,80016,100410171922
16,10016,400614242831
16,40016,700918313541
16,70017,0001123374350
17,00017,5001329465462
17,50018,0001737566877
18,00018,5002044688193
18,50019,00024518094108
19,00019,500275990108124
19,50020,0003067101121139
20,00020,5003474113134154
20,50021,0003782123148170
21,00021,5004189135161185
21,50022,0004497146174201
22,00023,00049108163194224
23,00024,00056123185221255
24,00025,00063138207248285
25,00026,00070153229275316
26,00027,00077168251302347
27,00028,00083183274328378
28,00029,00090198296355409
29,00030,00097213318382439
30,00031,000104228341408470
31,00032,000111243363435501
32,00033,000118258385461532
33,00034,000125273407488563
34,00035,000131288430515593
35,00036,000138303452542624
36,00037,000145318474568656
37,00038,000152333496595686
38,00039,000159348519621717
39,00040,000166363541648748
40,00041,000172378564674779
41,00042,000179393586701810
42,00043,000186408608728840
43,00044,000193423630755871
44,00045,000200438652782902
45,00046,000207453674809933
46,00047,000213468697835964
47,00048,000220483719862995
48,00049,0002274987428881,025
49,00050,0002345137649151,056
50,00051,0002415287869421,087
51,00052,0002485438089691,117
52,00053,0002545588319951,148
53,00054,0002615738531,0221,179
54,00055,0002685888751,0491,210
55,00056,0002756038971,0761,241
56,00057,0002826189201,1021,271
57,00058,0002896339421,1281,303
58,00059,0002966489641,1551,334
59,00060,0003026639871,1821,364
60,00062,0003136851,0201,2221,411
62,00064,0003267161,0641,2761,472
64,00066,0003407461,1081,3291,534
66,00068,0003547751,1541,3821,595
68,00070,0003678061,1981,4351,657
70,00072,0003818361,2421,4891,719
72,00074,0003958651,2871,5431,780
74,00076,0004088961,3311,5961,842
76,00078,0004229261,3761,6491,903
78,00080,0004369551,4211,7031,965
80,00085,0004601,0081,4981,7962,074
85,00090,0004941,0831,6101,9292,228
90,00095,0005281,1581,7212,0632,382
95,000100,0005621,2331,8332,1962,536
100,000110,0006141,3461,9992,3962,767
110,000120,0006821,4962,2222,6633,075
120,000130,0007501,6462,4442,9313,383
130,000140,0008191,7962,6673,1973,692
140,000150,0008871,9462,8903,4644,000
150,000160,0009562,0963,1123,7314,308
160,000170,0001,0242,2463,3353,9984,616
170,000180,0001,0932,3963,5574,2664,924
180,000190,0001,1612,5463,7804,5325,233
190,000200,0001,2292,6964,0034,7995,541
200,000210,0001,2982,8464,2255,0675,848
210,000220,0001,3662,9964,4485,3336,157
220,000230,0001,4353,1464,6715,6006,465
230,000240,0001,5033,2964,8935,8676,774
240,000and up1,5713,4465,1166,1347,082
REV. PROC. 2007-30 TABLE 4
DOLLAR AMOUNTS FOR TRUCKS AND VANS WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2007
---------------------
Fair Market Value of Truck or VanTax Year During Lease
---------------------
OverNot Over1st2nd3rd4th5th and later
---------------------
$16,400$16,7002481011
16,70017,00049151721
17,00017,500615242833
17,50018,0001022354248
18,00018,5001330465564
18,50019,0001737576979
19,00019,5002045688294
19,50020,00024528095109
20,00020,500276090109125
20,50021,0003067102122141
21,00021,5003475113135156
21,50022,0003782124149171
22,00023,0004294140169194
23,00024,00049109163195225
24,00025,00056123186222256
25,00026,00063138208249286
26,00027,00070153230276317
27,00028,00077168252302349
28,00029,00083184274329379
29,00030,00090199296356410
30,00031,00097214318383440
31,00032,000104228342408472
32,00033,000111243364435503
33,00034,000118258386462534
34,00035,000125273408489564
35,00036,000131289430515595
36,00037,000138304452542626
37,00038,000145318475569657
38,00039,000152333497596688
39,00040,000159348520622718
40,00041,000166363542649749
41,00042,000172379563676780
42,00043,000179394586702811
43,00044,000186409608729842
44,00045,000193423631756872
45,00046,000200438653783903
46,00047,000207453675810934
47,00048,000213469697836965
48,00049,000220484719863996
49,00050,0002274997418901,026
50,00051,0002345147649161,057
51,00052,0002415287879431,088
52,00053,0002485438099691,119
53,00054,0002545598319961,150
54,00055,0002615748531,0231,180
55,00056,0002685898751,0501,211
56,00057,0002756048971,0761,243
57,00058,0002826189201,1031,273
58,00059,0002896339431,1291,304
59,00060,0002966489651,1561,335
60,00062,0003066719981,1961,381
62,00064,0003197011,0431,2491,443
64,00066,0003337311,0871,3031,504
66,00068,0003477611,1311,3571,566
68,00070,0003617911,1761,4101,627
70,00072,0003748211,2211,4631,689
72,00074,0003888511,2651,5171,751
74,00076,0004028811,3091,5701,813
76,00078,0004159111,3541,6241,874
78,00080,0004299411,3991,6761,936
80,00085,0004539941,4761,7702,044
85,00090,0004871,0691,5871,9042,198
90,00095,0005211,1441,6992,0372,352
95,000100,0005551,2191,8102,1712,506
100,000110,0006071,3311,9772,3712,737
110,000120,0006751,4812,2002,6383,045
120,000130,0007441,6312,4232,9043,354
130,000140,0008121,7812,6463,1713,662
140,000150,0008801,9322,8673,4393,970
150,000160,0009492,0813,0913,7054,279
160,000170,0001,0172,2323,3133,9724,586
170,000180,0001,0862,3813,5364,2394,895
180,000190,0001,1542,5323,7584,5065,203
190,000200,0001,2222,6823,9814,7735,511
200,000210,0001,2912,8314,2045,0405,820
210,000220,0001,3592,9824,4265,3076,128
220,000230,0001,4283,1314,6495,5756,435
230,000240,0001,4963,2824,8715,8416,744
240,000and up1,5653,4315,0956,1087,052

SECTION 5. EFFECTIVE DATE

This revenue procedure applies to passenger automobiles (other than leased passenger automobiles) that are first placed in service by the taxpayer during calendar year 2007, and to leased passenger automobiles that are first leased by the taxpayer during calendar year 2007.

SECTION 6. DRAFTING INFORMATION

The principal author of this revenue procedure is Bernard P. Harvey of the Office of Associate Chief Counsel (Passthroughs & Special Industries). For further information regarding the depreciation limitations and lessee inclusion amounts in this revenue procedure, contact Bernard P. Harvey at (202) 622-3110 (not a toll-free call).

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