Rev. Rul. 99-33, 1999-34 I.R.B. 251.

                       Internal Revenue Service
                                 Revenue Ruling

                   FRINGE BENEFITS AIRCRAFT VALUATION FORMULA

                           Published: August 23, 1999

Section 61.--Gross Income Defined, 26 CFR 1.61-21: Taxation of fringe benefits.

  Fringe benefits aircraft valuation formula. For purposes of section 1.61- 21(g) of the Income Tax Regulations, relating to the rule for valuing noncommercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL), cents-per-mile rates, and terminal charges in effect for the second half of 1999 are set forth.

  Fringe benefits aircraft valuation formula. For purposes of section 1.61- 21(g) of the Income Tax Regulations, relating to the rule for valuing non- commercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL), cents-per-mile rates, and terminal charges in effect for the second half of 1999 are set forth.

  For purposes of the taxation of fringe benefits under section 61 of the Internal Revenue Code, section 1.61-21(g) of the Income Tax Regulations provides a rule for valuing noncommercial flights on employer-provided aircraft. Section 1.61-21(g)(5) provides an aircraft valuation formula to determine the value of such flights. The value of a flight is determined under the base aircraft valuation formula (also known as the Standard Industry Fare Level formula or SIFL) by multiplying the SIFL cents-per-mile rates applicable for the periods during which the flight was taken by the appropriate aircraft multiple provided in section 1.61-21(g)(7) and then adding the applicable terminal charge. The SIFL cents-per-mile rates in the formula and the terminal charge are calculated by the Department of Transportation and are reviewed semiannually.

  The following chart sets forth the terminal charges and SIFL mileage rates:
Period During Which the Flight  Terminal      SIFL Mileage Rates
  Is Taken                        Charge
7/1/99-12/31/99                 $32.41        Up to 500 miles = $.1773 per mile
                                              501-1500 miles = $.1352 per mile
                                              Over 1500 miles = $.1300 per mile

DRAFTING INFORMATION

  The principle author of this revenue is Kathleen Edmondson of the Office of the Associate Chief Counsel (Employee Benefits and Exempt Organizations). For further information regarding this revenue ruling, contact Ms. Edmondson on (202) 622-6080 (not a toll-free call).

Rev. Rul. 99-33, 1999-34 I.R.B. 251.