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No, it's not a luxury car, at least not in Colorado.

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So, I'm trying to get a luxury limo license for my Model S in Colorado and Tesla is not listed as a manufacturer of luxury cars in this State. I need to "prove" it's a luxury vehicle and petition for a "rule making" from the Public Utilities Commission.

To that end- any links or evidence which anyone can provide proving the luxury status of a Tesla Model S would be greatly appreciated. All direct comparisons with cars which Colorado does call luxury cars would also be helpful.

Here are the cars which Colorado *does* accept as an "executive car" luxury brands:

(A)a sedan, crossover, or sport utility vehicle manufactured by: Acura, Audi,
Bentley, BMW, Cadillac, Ferrari, Infiniti, Jaguar, Lexus, Lincoln, Maserati,
Mercedes-Benz, Porsche, or Rolls Royce; or
(B) one of the following: Chrysler 300, Hyundai Equus, Saab 9-5, Chevrolet
Suburban, Chevrolet Tahoe, Ford Excursion, Ford Expedition, GMC Yukon,
Hummer (all models, excluding sport utility truck version).
 
Luxury Limousine Features.
(a) In addition to compliance with the safety rules, each luxury limousine carrier shall otherwise ensure that its motor vehicles are in good physical condition. The Commission shall use the following guidelines in determining if a vehicle is in good physical condition:
(I) The body of the luxury limousine has a good, unfaded paint job; is devoid of dents, rust, broken trim, and cracked windows; and
(II) Except for problems caused by current weather conditions, the interior of the luxury limousine is clean, free of offensive odors, and has no major tears, cracks, or stains upon the upholstery, headliner, and carpeting.
(b) Age of Motor Vehicles. Except for luxury limousines covered under subparagraph 6308(a)(IV), luxury limousine carriers shall not use vehicles older than ten model years as of July 1 of each year. For purposes of this rule, the counting of model years shall begin with the present calendar year. By way of example, between July 1, 2011, and June 30, 2012, counting backwards, 2011 is the first model year, 2010 is the second model year, and so forth.


6308. Luxury Limousine.
(a) A luxury limousine is:
(I) Stretched limousine, which is a motor vehicle whose wheelbase has been lengthened beyond the original manufacturer's specifications.
(II) Executive car, which is a motor vehicle that has four doors and is:
(A) a sedan, crossover, or sport utility vehicle manufactured by: Acura, Audi, Bentley, BMW, Cadillac, Ferrari, Infiniti, Jaguar, Lexus, Lincoln, Maserati, Mercedes-Benz, Porsche, or Rolls Royce; or
(B) one of the following: Chrysler 300, Hyundai Equus, Saab 9-5, Chevrolet Suburban, Chevrolet Tahoe, Ford Excursion, Ford Expedition, GMC Yukon, Hummer (all models, excluding sport utility truck version).
(III) Executive van, which is a motor vehicle built on a cutaway chassis, a motor coach, or a van (but not a minivan as classified by the original manufacturer) whose interior has been enhanced by the installation of either:
(A) Captain’s chairs, couch seats, or similar seating in place of standard bench seating; or
(B) Both of the following:
(i) An electronic video media system such as television with DVD that is securely attached to the motor vehicle in a professional manner. The screen shall have a diagonal measurement of at least ten inches, be viewable by passengers seated to the rear of the driver, and be in compliance with 49 C.F.R., § 393.88.
(ii) Beverages and beverage service amenities, including at least an ice container and glasses or cups. The beverages and amenities shall be securely positioned inside a console or cabinet located inside the passenger compartment, to include any containment system, console and cup holder built into the motor vehicle by the manufacturer, and securely attached to the motor vehicle in a professional manner. The beverages are not required to be alcoholic in nature.
(IV) Other limousine, which is a classic, antique, or specially built motor vehicle that has or had a retail value of $50,000.00 or more.
 
I cannot seem to find info for the most current tax year, but look into the IRS rules for depreciation of a luxury vehicle. Apparently the definition used by the IRS is very favorable -- something like $16,000. That may be so comically low it loses credibility for your purposes, though.
 
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There's also a colorable argument that the Model S is a "specially built motor vehicle that has or had a retail value of $50,000.00 or more." Though given the context of the rest of that provision, that probably wasn't the intent.