Sprint Corporation and Subsidiaries, f.k.a. United Telecommunications, Inc. - Page 43

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          intangible character, is appropriate.  Petitioner contends that             
          its costs should be amortized over a period no shorter than 60              
          months pursuant to section 4.01(2) of Rev. Proc. 69-21, 1969-2,             
          C.B. 303.  Respondent contends that the software should be                  
          depreciated over 18 years, the asset guideline period for central           
          office equipment (COE), for the software was an integral part of            
          the COE.                                                                    
               Rev. Proc. 69-21, supra, provides in section 4.01:                     
                    (.01) With respect to costs of purchased software, the            
               Service will not disturb the taxpayer's treatment of such              
               costs if the following practices are consistently followed:            
                           *    *    *    *    *    *    *                            
                         2.  Where such costs are separately stated, and              
                    the software is treated by the taxpayer as an                     
                    intangible asset the cost of which is to be recovered             
                    by amortization deductions ratably over a period of               
                    five years or such shorter period as can be established           
                    by the taxpayer as appropriate in any particular case             
                    if the useful life of the software in his hands will be           
                    less than five years.                                             
          Under this revenue procedure, if the taxpayer uses a period                 
          shorter than 5 years, he must establish that the useful life is             
          less than 5 years; otherwise, the Commissioner will let stand the           
          amortization period.                                                        
               The software was separately stated on petitioner's books and           
          in its purchase invoices from the assets from which it was                  
          purchased.  The only issue is whether petitioner treated the                
          software as an intangible asset.  Petitioner did not originally             
          amortize the software pursuant to this revenue procedure but                
          rather treated the software and COE as one whole asset and                  



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