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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,
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