Work is performed only on engines that have been separated from their aircraft. An engine is subject to heavy maintenance if it contains components that have reached their operational time limit.
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Heavy maintenance involves the complete disassembly of the engine, the piece-by-piece inspection of every component, and the restoration of each component to its original form and specifications. Engines that fall within the light maintenance category are those that do not require a complete overhaul, although the work involved may include a complete restoration of an engine module.
Light maintenance may require as little as two to three days or as many as twenty-five to thirty-five days to complete. Heavy maintenance may require from 45 to 70 days to complete, depending on the type of engine.
Delta estimates it would incur approximately twice the cost for outsourcing its engine overhauls. Delta also manufactures aircraft parts from raw materials at the TOC. The types of parts made range from routine to specialized pieces based on blueprint drawings. Delta stores airplane parts in a warehouse and ships them to its airport stations in other states as needed. Under the revised statute, remanufacturing of aircraft engines is defined as the substantial overhauling or rebuilding of aircraft engines.
The legislature obviously intended that aircraft engines in the process of remanufacture would qualify for the freeport exemption. Delta claimed the Category 1 freeport exemption for all engines undergoing heavy maintenance as well as all large engines undergoing light maintenance.
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Delta did not claim the exemption for small engines undergoing light maintenance. The apparent reason for the division was that work on the larger engines was more costly. The record indicates that light maintenance varies from what could best be characterized as a repair lasting several days to substantial and time-consuming rebuilding over a period of several weeks.
Accordingly, we hold that this issue merits submission to a jury. The Board has raised a number of issues which they claim preclude the availability of the Category 1 freeport exemption to Delta.
Although we discuss each of the Board's contentions in some detail below, we find none have merit. In construing a legislative act, a court must first look to the literal meaning of the act. Inventory of a person is not to be classified as his equipment. The engines claimed by Delta under the Category 1 exemption qualify as works in progress.
The finished goods claimed by Delta under the Category 2 and Category 3 exemptions are parts consumed in its business operations. We find no merit in this argument. As discussed in Division 1 a supra, the record indicates that the process of substantial overhauling involves the alteration or replacement of all or a significant portion of the internal components of an engine. The process physically changes the engine, as well as changing the function of the engine so it is again qualified to serve on an aircraft. Contrary to the Board's argument, this process differs dramatically from that used to package cookies, thus distinguishing this case from Murray Bakery Products v.
The fact that Delta is in the transportation business is not fatal to Delta's claim for a Category 1 exemption.
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The record indicates that Delta functions as a manufacturer of aircraft parts and a remanufacturer of aircraft engines in the regular course of its business, and that those operations are located in this state. The Board claims that because the voters of Clayton County did not approve the freeport exemption after the amendment addressing the remanufacture of airplane engines 21 became effective, the Category 1 exemption does not apply to such remanufacture.
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The Board's position contemplates that county voters must hold a referendum to approve every amendment affecting the freeport tax exemption. Clearly, that is not required.
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The voters approve the freeport tax exemption, but the Georgia Constitution delegates the details of implementing the exemption to the legislature. It is apparent from the record that the engines were in various stages of work, and that physical work had not begun on each of them. However, as long as an engine enters the process of remanufacture, whether it be in the diagnostic stage or awaiting an open bin for work to begin, the extent of an engine's progress toward completion of the process need not be considered.
Finally, the Board claims that the freeport exemption is unconstitutional. This claim is not supported by argument, and we will not consider it. Accordingly, we hold that the trial court erred in granting summary judgment to the Board on Delta's claim for the Category 1 freeport exemption. The Board claims that Delta's application for the Category 2 exemption was incomplete because it did not contain a list of the specific parts for which the exemption was claimed.
Delta completed an official freeport application form according to the form's specifications.
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We decline to do so here. We find that Delta properly completed the application for a Category 2 freeport exemption. The Category 2 exemption only applies to parts held less than a year after they are manufactured. The record indicates that Delta considered the time requirement in completing the application, and that its inventory of manufactured parts turns over from two to six times per year, depending on the part.
This is evidence that the month time limit was satisfied. However, the Board presented evidence that Delta held the property for more than 12 months. Property tax payments may be mailed to the City of Forest Park, P. Box 69, Forest Park, Georgia The City accepts cash, check, money order or credit card payments.
If your taxes are included in your mortgage payments, please send a copy of the property tax bill to your mortgage company. The City of Forest Park does not send a duplicate copy to mortgage companies; the original bill is sent directly to the property owner. Download Our Apps.
The field appraiser will have a photo identification badge and will be driving an appropriately marked vehicle. Should you have any questions or concerns, please do not hesitate to contact the Clayton County Assessors Office at IAAO Member The Tax Assessors Office is responsible for the preparation of the annual real and personal property tax digest in compliance with the taxation laws of the state.
The following information is furnished by the Clayton County Board of Tax Assessors and is not intended to be a statement of law.
It is solely for the purpose of assisting Clayton County property owners. The Board of Tax Assessors, an independent body appointed by the Board of Commissioners, is responsible for placing a fair and equalized value on all taxable property. The Board of Commissioners sets the millage rate.
The billing and collection of taxes is the responsibility of the Tax Commissioner. January 1 of each year is the assessment date in Georgia. Accordingly, all property must be valued for ad valorem taxes based on its condition and use as of January 1.