IRS Notice 2013-3

(by presumption, IRS has historically treated dual-use property (property held for sale or lease) that dealer holds as inventory property not eligible for depreciation; presumption rebuttable if dealer can establish that property actually used in dealer's trade or business and cost recovered through use in business; dealers in construction and ag equipment are typically resellers or enter into leases (under which the property is either reacquired at end of lease or purchased by lessee); in Notice, IRS requesting comments as to whether construction and ag equipment held for sale or lease to customers should be treated as inventory or depreciable property, and under what circumstances the property would qualify for like-kind exchange treatment).