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There are exceptions from the asset category for items classified in
the activity category and vice versa. We are not convinced that the
activity categorization of class 57.0 is more specific than the
asset categorization of class 00.11 in the case of office furniture
and fixtures. Petitioner’s suggested rule of construction is of no
help to it here.
Respondent argues that the plain language of Rev. Proc. 87-56
provides that the asset category consists of “Specific Business
Assets Used in All Business Activities” and that the inclusive
adjective, “all”, plainly establishes a priority of asset
categorization over activity categorization, except where a specific
exception applies. We do not agree. The adjective “all” simply
serves to define a class in the category; it does not help solve the
priority question raised by a class in the activity category that,
on its face, also includes the furniture and fixtures. Respondent
also argues that his position is supported by the history of the
asset depreciation guidelines. We have already discussed some of
that history, but, at the risk of repeating ourselves, will set
forth respondent’s argument:
Rev. Proc. 87-56's predecessors all grouped depreciable
assets into the same two broad categories, specific assets
used in all business activities and assets used in
specific business activities. See, Rev. Proc. 83-35,
1983-1 C.B. 745; Rev. Proc. 77-10, 1977-1 C.B. 548; and
Rev. Proc. 72-10, 1972-1 C.B. 721. Those revenue
procedures were patterned after the first depreciation
guideline revenue procedure, Rev. Proc. 62-21, 1962-2 C.B.
418. Rev. Proc. 62-21 provided for four groups of
depreciable assets. The first group, corresponding to the
asset category of Rev. Proc. 87-56, consisted of assets
used by business in general. The second, third, and
fourth groups, corresponding to the activity category of
Rev. Proc. 87-56, consisted of assets used in non-
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