Sprint Corporation and Subsidiaries, f.k.a. United Telecommunications, Inc. - Page 16

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          (1) Sprint owned the software in issue and (2) the software                 
          qualifies as tangible personal property.                                    
               Respondent concedes that if Sprint in fact owned the                   
          software and the software constitutes tangible property, Sprint             
          is entitled to the ITC and accelerated depreciation, as claimed.            
          If Sprint did not own the software in issue, or if the software             
          is not tangible personal property, respondent contends that                 
          Sprint is entitled to amortize the cost of the software on a                
          straight-line basis over an 18-year period, while Sprint contends           
          that the costs should be amortized in accordance with Rev. Proc.            
          69-21, sec. 4.01(2), 1969-2 C.B. 303.  The 18-year period is the            
          class life asset depreciation range (CLADR) midpoint life of the            
          switch hardware with which the software is associated.  Rev.                
          Proc. 69-21, sec. 4.01(2), supra, is the procedure pursuant to              
          which, during 1982 through 1985, Sprint capitalized and amortized           
          the cost of purchased software, other than the software purchased           
          in connection with the digital switches (rather than claiming the           
          ITC and accelerated depreciation under the ACRS).                           
          B.  Drop and Block Issue                                                    
               A telephone network includes transmission facilities and               
          station equipment (or station apparatus).  Transmission                     
          facilities consist of the wiring and ancillary equipment used to            
          transmit telephone signals between the telephone company's                  
          central office and the customer's (whether caller or callee)                
          station apparatus (i.e., telephone, modem, or other device).                




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