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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. As pertinent here, Rev. Proc. 87-
56, 1987-2 C.B. 677, provides the following asset guideline
classes:
00.3 Land Improvements:
Includes improvements directly to or added to land,
whether such improvements are section 1245 property or
section 1250 property, provided such improvements are
depreciable. Examples of such assets might include
sidewalks, roads, canals, waterways, drainage
facilities, sewers, * * * wharves and docks, bridges,
fences, landscaping, shrubbery, or radio and television
transmitting towers. Does not include land improvements
that are explicitly included in any other class, and
buildings and structural components as defined in
section 1.48-1(e) of the regulations. * * *
* * * * * * *
01.3 Farm buildings except structures included in Class 01.4
01.4 Single purpose agricultural or horticultural
structures (within the meaning of section 48(p) of the
Code).
Assets includable in class 00.3 have a class life of 20
years and, by virtue of section 168(e)(1) are 15-year property,
with an applicable recovery period of 15 years. See sec.
168(c)(1). Assets includable in class 01.3 have a class life of
25 years and, by virtue of section 168(e)(1) are 20-year
property, with an applicable recovery period of 20 years. See
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