- 42 -
1983-1 C.B. 745.28 Rev. Proc. 87-56, sec. 2.20, 1987-2 C.B. at
674. Section 168(i)(1)(B) provides that, except in the case of
residential rental property or nonresidential real property,
respondent may designate a class life for any property which does
not have a prescribed class life as of January 1, 1986, or,
within restrictions, may modify the class life of property.29
See sec. 168(i)(1)(D). Additionally, section 168(e) assigns
recovery periods to certain tangible, depreciable property
regardless of its class life. Sec. 168(e)(3). Rev. Proc. 87-56,
section 5, 1987-2 C.B. 674, as clarified and modified by Rev.
Proc. 88-22, 1988-1 C.B. 785, prescribes class lives and recovery
periods applicable for years ended 1987 and 1988.
MACRS repealed ACRS section 168(f)(1), which related
specifically to components of section 1250 class property.
Section 168(i)(6),30 however, provides that improvements made to
28 With the exception of telephone central office equipment for
which a class life was delineated in Rev. Proc. 82-67, 1982-2
C.B. 853, the class lives for property as of Jan. 1, 1986, for
property that had assigned class lives, remained the same as
their class lives as of Jan. 1, 1981. See Collins Music Co. v.
United States, 21 F.3d 1330, 1333-1334 (4th Cir. 1994); Rev.
Proc. 83-35, sec. 1.01, 1983-1 C.B. 745, 745.
29 Congress repealed respondent's authority to prescribe or
modify class lives in sec. 6253 of the Technical and
Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat.
3753.
30 Sec. 168(i)(6) provides as follows:
(6) Treatments of additions or improvements to
property.--In the case of any addition to (or improvement
(continued...)
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