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depreciable over 5 years and property in FCC account No. 242 as
depreciable over 15 years. In petitioner's 1984 and 1985 Federal
income tax returns, the following subsidiaries of petitioner
continued to account for drop and block in FCC account No. 232,
treating it as 5-year property for depreciation purposes:
Company
UT of PA & Saltillo Carolina T&T
UT of New Jersey UT of Florida
New Jersey Tel. Co. United Intermountain
West Jersey Tel. Co. UT of Carolinas
Hillsborough-Montgomery UT of Indiana
Sussex Tel. Co. (D) UT of the Northwest
UT of Ohio UT Texas & Palo Pinto
In petitioner's 1984 and 1985 Federal income tax returns,
the following subsidiaries of petitioner accounted for drop and
block in FCC account No. 242, treating it as 15-year public
utility property for depreciation purposes:
Company
UT Arkansas
UT Iowa
UT Kansas
UT Minnesota
UT Missouri
UT West
Respondent concedes that, if the drop and block property
placed in service during the years in issue is properly
classified by reference to its pre-January 1, 1984, inclusion in
FCC account No. 232 and CLADR Asset Guideline Class 48.13, then,
with the exception of the depreciation described in the preceding
paragraph, the depreciation claimed with respect to that drop and
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