Hospital Corporation of America and Subsidiaries - Page 58

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          eligible personal property and certain real property as 3-year              
          property, 5-year property, 7-year property, 10-year property, 15-           
          year property, or 20-year property, and assigns that property to            
          a corresponding recovery period on the basis of the property's              
          class life.  Sec. 168(c), (e)(1), (e)(3).  MACRS generally                  
          classifies section 1250 real property as residential rental                 
          property (which is not involved in the instant case) or                     
          nonresidential real property,26 which are assigned to a 27.5-year           
          recovery period or a 31.5-year recovery period,27 respectively.             
          Sec. 168(c), (e)(2).                                                        
               Section 168(i)(1) provides that the term "class life" means            
          "the class life (if any) which would be applicable with respect             
          to any property as of January 1, 1986, under subsection (m) of              
          section 167".  That class life generally is the midpoint class              
          life for the asset guideline class to which the property was                
          assigned as of January 1, 1986, pursuant to Rev. Proc. 83-35,               



          26   Sec. 168(e)(2)(B) defines nonresidential real property as              
          follows:                                                                    
               (B) Nonresidential real property.--The term "nonresidential            
               real property" means section 1250 property which is not--              
                    (i) residential rental property, or                               
                    (ii) property with a class life of less than 27.5                 
               years.                                                                 
          27   OBRA-1993, sec. 13151, 107 Stat. 448, extended to 39 years             
          the recovery period for nonresidential real property placed in              
          service after May 12, 1993.                                                 



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