- 53 -
The legislative history does not reveal a contrary
intention. The legislative history relating to section
168(f)(1)(A) does not focus on the definition of section 1250
class property or on the definition of structural components
contained in section 1.48-1(e), Income Tax Regs. See H. Rept.
97-201, at 67-68, 84 (1981); S. Rept. 97-144 (1981), 1981-2 C.B.
412, 428. Moreover, the General Explanation of ERTA prepared by
the staff of the Joint Committee on Taxation states as follows:
The recovery period and method the taxpayer selects
must be used for the building as a whole, including all
structural components that are real property (e.g., wiring,
plumbing, etc.). Component depreciation no longer may be
used. The distinction between a structural component of a
building, which is section 1250 property, and an item of
property that is section 1245 property remains the same as
under prior law. * * * [Staff of the Joint Comm. on
Taxation, General Explanation of the Economic Recovery Tax
Act of 1981, at 85 (J. Comm. Print 1981). Emphasis added.]
Additionally, see Staff of the Joint Comm. on Taxation,
General Explanation of the Tax Reform Act of 1986, at 90 (J.
Comm. Print 1987), summarizing the prohibition against the
component method of depreciation under ACRS as follows:
"Component cost recovery was not permitted under ACRS. Thus, the
same recovery period and method had to be used for a building as
a whole, including all structural components."; see also H. Rept.
99-426, at 138 (1985), 1986-3 C.B. (Vol. 2) 138; S. Rept. 99-313,
99th Cong., 2d Sess. 88 (1986), 1986-3 C.B. (Vol. 3) 88.
We note further that our understanding of the statutory
provision comports with the construction given that provision in
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