- 87 -
manufacturing activities, manufacturing activities, and
transportation, communication, and public utilities,
respectively. Specifically excluded from the second,
third, and fourth groups were any assets coming within the
first group. Although Rev. Proc. 87-56 and its immediate
predecessors do not explicitly exclude from the activity
category assets coming within the asset category, all
continue the same pattern.9
9 The legislative history of ACRS indicates that Congress
understood Rev. Proc. 87-56's predecessors as providing
that assets which are encompassed in classes in both the
asset and activity categories are to be classified in the
asset class. In describing the ADR system which was
incorporated into ACRS, the Conference Committee Report on
the Tax Reform Act of 1986 states: Under the ADR system, a
present class life ("mid-point") was provided for all
assets used in the same activity, other than certain
assets with common characteristics (e.g., automobiles).
H.R. Conf. Rep. No. 99-841, 99th Cong., 2d Sess. 38
(1986), 1986-3 C.B. Vol. 4, 38 (emphasis added)
(automobiles comprised an asset category class (Class
00.22) under Rev. Proc. 83-35, 1983-1 C.B. 745).
We are not interpreting a statutory provision. Although
Congress clearly was concerned with the Commissioner’s
implementation of the class life system, and the system implements
section 167, we are interpreting an administrative creation, and,
thus, we must determine the administrator’s intent. We are
persuaded by respondent that Rev. Proc. 62-21 established a pattern
that was carried over into subsequent revenue procedures, including
Rev. Proc. 87-56. Notwithstanding the failure to continue a
specific priority rule in subsequent revenue procedures, there is
sufficient similarity in style and organization between Rev. Proc.
62-21 and its successors that we think that a similar priority rule
was intended, and we so find.
E. Conclusion
The furniture and fixtures are described in class 00.11.
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