- 10 - production facility, which, as such, brings them within asset class 46.0. See sec. 1.167(a)-11(b)(4)(iii)(b), Income Tax Regs. Our conclusions herein are supported by our understanding of the evolution of asset class 13.2. In Rev. Proc. 62-21, 1962-2 C.B. 418, the Commissioner began grouping assets into broad industry classes for depreciation purposes. Group Three, Guideline Class 17(b), entitled "Exploration, Drilling and Production" states: "Includes the exploration, drilling, maintenance and production activities of petroleum and natural gas producers. Includes gathering pipelines and related storage facilities of such producers. Excludes gathering pipelines and related storage facilities of pipeline companies." Id. at 424. Under this description, petitioner's gathering systems clearly would not have been included in this class because the pipelines are owned by a pipeline company and not a producer. Later, when the Commissioner prescribed the asset classes and guideline lives for purposes of the asset depreciation range system, the Commissioner carried forward a similar limitation. Rev. Proc. 71-25, 1971-2 C.B. 553, 556, provides that asset class 13.2 "Includes assets used for drilling of wells and production of petroleum and natural gas, including gathering pipelines and related storage facilities, when these are related activities undertaken by petroleum and natural gas producers." After restating this description without change, see Rev. Proc. 72-10,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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