- 16 - (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).Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011