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producers and others consisting of platforms * * *,
compression or pumping equipment, and gathering and
transmission lines to the first onshore transshipment
facility * * *. * * *
Asset Class 46.0--Pipeline Transportation:
Includes assets used in the private, commercial, and
contract carrying of petroleum, gas and other products
by means of pipes and conveyors. The trunk lines and
related storage facilities of integrated petroleum and
natural gas producers are included in this class. * * *
Asset Class 49.23--Natural Gas Production Plant:
[No description given].
Rev. Proc. 87-56, supra, 1987-2 C.B. at 677, 678, 684, 686. A
15-year recovery period is assigned to property within either
asset class 46.0 or asset class 00.3. A 7-year recovery period
is assigned to property within either asset class 13.2 or asset
class 49.23. Sec. 168(c), (e)(1); see also Rev. Proc. 87-56,
supra, 1987-2 C.B. at 677, 678, 684, 686. Property without a
class life generally has a 7-year recovery period. Sec.
168(e)(3)(C).
Asset class 13.2 and asset class 46.0, when read together,
refer to assets used in the process that starts with the drilling
and removal from the ground of petroleum and natural gas
(production) and ends with the transportation of the gas to its
end use. The question, therefore, is whether petitioner's
gathering systems produce or transport gas. We conclude that
they transport gas. The gathering systems are primarily
pipelines that are used by a nonproducer privately, commercially,
and/or contractually to carry gas; they are not used by a
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