ABC Rentals of San Antonio, Inc. - Page 16

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          deduction would be allowable for the rental unit.  Section                  
          168(f)(1) provides:                                                         
                    (f) Property to Which Section Does Not Apply.--This               
               section shall not apply to--                                           
                         (1) Certain methods of depreciation.--Any                    
                    property if--                                                     
                              (A) the taxpayer elects to exclude such                 
                         property from the application of this section, and           
                              (B) for the 1st taxable year for which a                
                         depreciation deduction would be allowable with               
                         respect to such property in the hands of the                 
                         taxpayer, the property is properly depreciated               
                         under the unit-of-production method or any method            
                         of depreciation not expressed in a term of years             
                         (other than the retirement-replacement-betterment            
                         method or similar method).                                   
               Section 2.02 of Revenue Procedure 87-57, 1987-2 C.B. 687,              
          688, provides that the election under section 168(f)(1) must be             
          made following the procedures set forth in section 2.10 of the              
          Revenue Procedure.  Section 2.10 of Revenue Procedure, 1987-2               
          C.B. at 689, provides,                                                      
                    .10 Time and manner for making elections.  Under                  
               section 5h.5(a)(2) of the temporary regulations, after April           
               14, 1987, an election described in this revenue procedure              
               shall be made by the due date (taking extensions into                  
               account) of the tax return for the first taxable year for              
               which the election is to be made.  The tax return must be              
               accompanied by a statement identifying the election by                 
               reference to Code or Act section and identifying the                   
               property items for which the election is being made.                   
               Section 5h.5, Temporary Tax Reform Act of 1986 Election                
          Regs., 52 Fed. Reg. 3624 (Feb. 5, 1987), effective February 5,              
          1987, applies to section 168(f)(1) elections and sets forth the             
          time and manner guidelines for elections made after October 22,             
          1986.  The election for section 168(f)(1) is available for                  
          property placed in service after December 31, 1986.  Section                


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