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AeroMarineTaxPros.com: The Dealer License Myth

Many times taxpayers call me when they
receive a notice from the Board ofThe following are summaries from some
Equalization (BOE); often they feel that theyannotations that establish the BOE's position
have been unfairly singled out. Many timesregarding  sale  for  resale:
they open the conversation with, "I have a
dealer's  license.  I don't have to pay tax."210.0019 Aircraft. The use of an aircraft by
an aircraft dealer to transport executives
Unfortunately, I have to be the one to breakand other people, when these people are not
the bad news. They have fallen prey to one ofpotential purchasers, is not a use for
the most insidious lies that resides in thedemonstration and display under Regulation
aircraft industry. Worse, this lie permeates1669. Such use is subject to tax as set forth
into many California businesses that don'tin  Regulation  1669(f)(1)(C).  6/29/71.
own  aircraft.
210.0580 Transportation of Executives-Or
IT IS NOT TRUE THAT A CALIFORNIA SELLER'SEngineering Tests. Aircraft to transport
PERMIT OR AN FAA DEALER'S LICENSE ALLOWS YOUexecutives and other people on one-way trips,
TO MAKE PURCHASES WITHOUT BECOMING LIABLE FORsuch people not being potential purchasers,
THE  TAX.or use of aircraft extensively for
engineering tests, do not constitute
If you or anyone you know is operating based''demonstration or display'' and are taxable
on this belief, have them call our officeuses.  1/12/55.
today. This is one of the areas that always
rank high on the BOE's list of "most commonThe BOE does allow certain flights that are
mistakes."not  for  demonstration  and  display.
If a taxpayer purchases an aircraft for210.0020 Aircraft. An airplane held for sale
resale, he is not allowed to make any use ofwhich is flown around the country to develop
the aircraft unless he can support throughinterest and which is used by the taxpayer to
documentation the use was for demonstrationkeep it in condition and to instruct himself
and display. Additionally, before you decidein its proper use, held not subject to use
to fly your aircraft for 500 hours a year andtax.  8/10/65.
claim all the flights are for demonstration
and display, be aware that the burden ofHowever, this is not a license to steal. The
proof is on the taxpayer. The use that isburden of proof is on the taxpayer. That
claimed for demonstration and display mustmeans documentation must be provided to
pass  what  I  call  the  "laugh  test."support the flights were for the purpose of
demonstrating it for sale. Don't misconstrue
Try describing your actual use of thethe "instruct" part as the right to use the
aircraft to any of the following. If youraircraft to get trained how to fly regardless
financial advisor rolls his eyes, yourof how long it takes. PLEASE REFER BACK TO
attorney falls face down in his soup, or theTHE  LAUGH  TEST!
tax auditor starts laughing so hard that
tears roll down from his eyes, then it doesIn certain cases the taxpayer can charge for
not  pass  the  laugh  test.demonstration  and  display  flights.
If you intend to claim the property was210.0060 Charge for Demonstration. If an
purchased  for  retail  you  better  have:aircraft is used solely for demonstration or
display purposes while being held for sale,
1. Copies of ongoing advertising that promotethe dealer will not incur liability for use
your  specific  aircraft  for  sale.tax simply because he makes a charge to the
prospective customer to whom the plane is
2. Name, address, and phone number for everydemonstrated but who fails to purchase the
person who was on a flight that you areplane, provided the charge is no more than
claiming  was  for demonstration and display.the actual expense incurred in the
demonstration. Notwithstanding the making of
3. Accurate flight logs for the specificthe charge, it does not appear that the law
aircraft.requires application of the tax if no actual
use of the article other than demonstration
4.  Fuel  receipts  that support each flight.while being held for sale is made. 6/21/57.



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