It appears that reality shows have taken over the airwaves. Some are staged and others just seem to capture life. One of my favorites is "American Chopper," where a father and two sons interact in a rather dysfunctional manner to build expensive, customized motorcycles.

Despite the vast number of reality shows, I think we are missing one that I am sure I as well as readers of Practical Accountant would be eager to watch: A show that focuses on the world in which accountants live and work.

To move things along, I thought I would develop the idea for a pilot that can be offered to the networks for the upcoming season. The opening shot would be this gargantuan vehicle barreling down a highway.

Let me offer a description of the vehicle so that you get a better idea of what the viewers will see. The vehicle tows trailers and semitrailers (trailers); the trailers exceed 35 feet in length and have a gross vehicle weight (GVW) rating of 20,000 pounds. It has a standard chassis cab (4-door with crew cab), accommodating five passengers, and is outfitted with certain luxury features.

The cab has an electric trailer brake control that connects to the brakes of a towed trailer and to a hook-up for trailer lights. The vehicle has two storage boxes behind the cab that can accommodate incidental items such as small tools and vehicle repair equipment.

The chassis cab has a GVW rating of 23,000 pounds and a gross combination weight rating of 43,000 pounds. The vehicle is equipped with hydraulic disc brakes with a four-wheel automatic braking system, a 300 horsepower engine, and a six-speed automatic transmission. The front axle of the vehicle has an 8,000-pound rating and the rear axle has a 15,000-pound rating. We're not done.

The vehicle has three types of hitching devices: a removable ball gooseneck hitch, a fifth wheel hitch, and a heavy duty trailer receiver hitch. The vehicle's platform, which is approximately 139 inches long, is designed with a rectangular well to accommodate the gooseneck and fifth wheel hitches (bed hitches). This platform slopes at the rear of the rectangular well and has tie-down hooks. Optional removable steel stake rails can be placed around the platform.

Although the vehicle is impressive, it won't carry the show by itself, so we need to add something else. No we are not going to add sex or violence. But, we are going to include conflict, so viewer interest can be sustained for the entire hour.

We will now bring IRS into the picture. We will put a couple of IRS agents with binoculars and a camcorder in a yellow Hummer following the vehicle.  The next shot would be in Washington, D.C. at the headquarters of the IRS. We could have a courtroom setting with a jury of 12 accountants answering the following all-important question: Is the vehicle described above a truck or a tractor for purposes of the retail excise tax imposed by Section 4051?

Whether the vehicle is a truck or a tractor is significant because the first retail sale of all highway tractors, regardless of size or use, is subject to the retail excise tax imposed by Section 4051. Trucks under a certain weight, however, are not subject to this tax.

Can't you feel the excitement building with viewers on the edge of their seat waiting for the jury's determination?

Don't worry. Even if the pilot doesn't get made, you can find out the answer and underlying, detailed, and involved reasoning. Simply read Rev. Rul. 2004-80. If don't have the time, here's the answer:

It is a tractor because the vehicle's physical characteristics, which maximize towing capacity at the expense of carrying capacity, establish that it is primarily designed to tow a vehicle, such as a trailer or semitrailer, rather than to carry cargo on its chassis.

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