AeroMarineTaxPros.com: The Dealer License Myth

Many times taxpayers call me when they receive a210.0019 Aircraft. The use of an aircraft by an
notice from the Board of Equalization (BOE); oftenaircraft dealer to transport executives and other
they feel that they have been unfairly singled out.people, when these people are not potential
Many times they open the conversation with, "I havepurchasers, is not a use for demonstration and
a dealer's license. I don't have to pay tax."display under Regulation 1669. Such use is subject to
Unfortunately, I have to be the one to break thetax as set forth in Regulation 1669(f)(1)(C). 6/29/71.
bad news. They have fallen prey to one of the most210.0580 Transportation of Executives-Or Engineering
insidious lies that resides in the aircraft industry.Tests. Aircraft to transport executives and other
Worse, this lie permeates into many Californiapeople on one-way trips, such people not being
businesses that don't own aircraft.potential purchasers, or use of aircraft extensively
IT IS NOT TRUE THAT A CALIFORNIA SELLER'Sfor engineering tests, do not constitute
PERMIT OR AN FAA DEALER'S LICENSE ALLOWS''demonstration or display'' and are taxable uses. 1/12
YOU TO MAKE PURCHASES WITHOUT BECOMING55.
LIABLE FOR THE TAX.The BOE does allow certain flights that are not for
If you or anyone you know is operating based ondemonstration and display.
this belief, have them call our office today. This is210.0020 Aircraft. An airplane held for sale which is
one of the areas that always rank high on the BOE'sflown around the country to develop interest and
list of "most common mistakes."which is used by the taxpayer to keep it in condition
If a taxpayer purchases an aircraft for resale, he isand to instruct himself in its proper use, held not
not allowed to make any use of the aircraft unlesssubject to use tax. 8/10/65.
he can support through documentation the use wasHowever, this is not a license to steal. The burden of
for demonstration and display. Additionally, beforeproof is on the taxpayer. That means documentation
you decide to fly your aircraft for 500 hours a yearmust be provided to support the flights were for the
and claim all the flights are for demonstration andpurpose of demonstrating it for sale. Don't
display, be aware that the burden of proof is on themisconstrue the "instruct" part as the right to use the
taxpayer. The use that is claimed for demonstrationaircraft to get trained how to fly regardless of how
and display must pass what I call the "laugh test."long it takes. PLEASE REFER BACK TO THE LAUGH
Try describing your actual use of the aircraft to anyTEST!
of the following. If your financial advisor rolls his eyes,In certain cases the taxpayer can charge for
your attorney falls face down in his soup, or the taxdemonstration and display flights.
auditor starts laughing so hard that tears roll down210.0060 Charge for Demonstration. If an aircraft is
from his eyes, then it does not pass the laugh test.used solely for demonstration or display purposes
If you intend to claim the property was purchasedwhile being held for sale, the dealer will not incur
for retail you better have:liability for use tax simply because he makes a charge
1. Copies of ongoing advertising that promote yourto the prospective customer to whom the plane is
specific aircraft for sale.demonstrated but who fails to purchase the plane,
2. Name, address, and phone number for everyprovided the charge is no more than the actual
person who was on a flight that you are claiming wasexpense incurred in the demonstration.
for demonstration and display.Notwithstanding the making of the charge, it does
3. Accurate flight logs for the specific aircraft.not appear that the law requires application of the
4. Fuel receipts that support each flight.tax if no actual use of the article other than
The following are summaries from some annotationsdemonstration while being held for sale is made. 6/21
that establish the BOE's position regarding sale for57.
resale: