Hospital Corporation of America and Subsidiaries - Page 60

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          real property are depreciated using the same recovery period                
          applicable to the underlying property as if the underlying                  
          property were placed in service at the time the improvements were           
          made.  Accordingly, MACRS continues the prohibition against the             
          use of the component method of depreciation.  S. Rept. 99-313, at           
          105 (1986), 1986-3 C.B. (Vol. 3) 105.                                       
               Congress did not assign a specific class life to the                   
          disputed property items placed in service during 1986 and 1987.             
          See sec. 168(e)(3).  Accordingly, the parties agree that the                
          disputed property items constitute 5-year property, as                      
          petitioners contend, only if the items have a class life of more            
          than 4 years but less than 10 years pursuant to Rev. Proc. 87-56,           
          as clarified and modified by Rev. Proc. 88-22, sec. 168(c),                 
          (e)(1), and the disputed property items do not constitute                   


          30  (...continued)                                                          
               of) any property--                                                     
                         (A) any deduction under subsection (a) for such              
                    addition or improvement shall be computed in the same             
                    manner as the deduction of such property would be                 
                    computed if such property had been placed in service at           
                    the same time as such addition or improvement, and                
                         (B) the applicable recovery period for such                  
                    addition or improvement shall begin on the later of--             
                              (i) the date on which such addition (or                 
                         improvement) is placed in service, or                        
                              (ii) the date on which the property with                
                         respect to which such addition (or improvement)              
                         was made is placed in service.                               




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