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Thomas P. Marinis, Jr., Sarah A. Duckers, and Charles T.
Fenn, for petitioner.
Emron M. Pratt, Jr. and Todd A. Ludeke, for respondent.
OPINION
LARO, Judge: The parties submitted this case to the Court
without trial. See Rule 122. Petitioner petitioned the Court to
redetermine respondent's determination of income tax deficiencies
of $399,369 and $753,089 for its taxable years ended
September 30, 1991, and September 30, 1992, respectively.
We must decide the cost recovery period of certain natural
gas recovery systems under the modified accelerated cost recovery
system (MACRS). Petitioner argues for a 7-year recovery period.
Respondent argues for a 15-year recovery period. We hold for
respondent. Unless otherwise noted, section references are to
the Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
References to "asset class" are to the asset classes set forth in
Rev. Proc. 87-56, 1987-2 C.B. 674.
Background
All facts are stipulated. The stipulated facts and exhibits
submitted therewith are incorporated herein by this reference.
Petitioner is the common parent of an affiliated group of
corporations which file consolidated Federal income tax returns.
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