Internal Revenue Service
Revenue Ruling

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Rev. Rul. 2000-40

Code Sec. 61;

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 period 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 charges. 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                        SIFL Mileage
Is Taken            Terminal Charge     Rates
________________    _______________     ____________
7/1/00-12/31/00     $34.57              Up to 500 miles
                                             = $.1891 per mile
                                        501-1500 miles
                                             = $.1442 per mile
                                        Over 1500 miles
                                             = $.1386 per mile
DRAFTING INFORMATION

The principal author of this revenue ruling is Kathleen Edmondson of the Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities). For further information regarding this revenue ruling, contact Ms. Edmondson on (202) 622- 6040 (not a toll-free call).