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The ADR was meant to objectify and standardize the useful lives
of assets by grouping assets into nearly 125 different asset
guideline classes, each with its own guideline period. See sec.
1.167(a)-11(b)(4)(i)(b), Income Tax Regs; Rev. Proc. 77-10, 1977-
1 C.B. 548. Taxpayers had to elect an asset depreciation period
from the ADR assigned to each guideline class, which was 80 to
120 percent of the asset guideline period. Sec. 1.167(a)-
11(b)(4)(i), Income Tax Regs. If no ADR was in effect, or if the
taxpayer did not elect to use the ADR system, the useful life was
determined with reference to the facts and circumstances
surrounding the asset. Simon v. Commissioner, supra.
In 1981, Congress enacted the ACRS by the Economic Recovery
Tax Act of 1981, Pub. L. 97-34, sec. 201, 95 Stat. 203. The ACRS
was meant to stimulate the economy by allowing greater
depreciation by taxpayers through shortened depreciation periods,
as well as simplifying depreciation calculations by reducing the
number of property classes from around 125 under the ADR system
to 5. It was expected that the reduction in the number of
property classes would help alleviate problems associated with
the complexity of the ADR depreciation system. S. Rept. 97-144,
at 47 (1981), 1981-2 C.B. 412, 425. The ACRS is mandatory and
must be used for most depreciable property placed in service
after 1980. Sec. 168(e)(1). Section 168, in relevant part,
provides:
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