Norwest Corporation and Subsidiaries, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries, et al. - Page 79

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          period with respect to the 1990-91 furniture and fixtures had been          
          put into play by respondent.  Section 6214 provides us with                 
          jurisdiction to determine an increased deficiency if a claim                
          therefor is asserted by the Secretary at or before the hearing.             
          Respondent has not relied on section 6214, so we assume that                
          respondent does not argue that he asserted a timely, appropriate            
          claim.  We conclude that the recovery period applicable to the 1990-        
          91 furniture and fixtures is not before the Court for decision.             
               B.   Applicable Recovery Period; Class Life                            
               Section 168(c) provides that the applicable recovery period of         
          5-year property is 5 years and the applicable recovery period of            
          7-year property is 7 years.  Section 168(e)(1) generally defines            
          5-year property as property having a class life of more than 4              
          years, but less than 10 years, and 7-year property as property              
          having a class life of 10 years or more, but less than 16 years.            
          “Class life”, as defined by section 168(i)(1), is determined by             
          reference to former section 167(m), as in effect prior to its repeal        
          by the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508,          
          sec. 11812(a), 104 Stat. 1388, 1388-534. Section 167(m) provided for        
          a depreciation allowance based upon the class life prescribed by the        
          Secretary of the Treasury or his delegate.  The class lives of              
          depreciable assets can be found in a series of revenue procedures           
          issued by the Commissioner.  See sec. 1.167(a)-11(b)(4)(ii), Income         
          Tax Regs.  The revenue procedure in effect for the years in issue in        
          this case is Rev. Proc. 87-56, 1987-2 C.B. 674 (Rev. Proc. 87-56).          
          Rev. Proc. 87-56 divides assets into two broad categories:  (1)             




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