- 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 inPage: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
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