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id. Finally, single purpose agricultural or horticultural
structures are, by virtue of section 168(e)(3)(D)(i), 10-year
property, with an applicable recovery period of 10 years. See
id.
Respondent contends that the Tobacco Barn is a "farm
building", a class 01.3 asset, and therefore has a recovery life
of 20 years. Petitioners contend that the Tobacco Barn has a
recovery period of 10 years because it is a single purpose
horticultural structure. As discussed above, the Tobacco Barn is
not a single purpose horticultural structure and therefore does
not have a 10-year recovery period as prescribed under section
168(e)(3)(D)(i).
In the alternative, petitioners contend that the Tobacco
Barn is a "land improvement", a class 00.3 asset, and therefore
has a recovery period of 15 years. As discussed above, the
Tobacco Barn is a building as defined under section 1.48-1(e),
Income Tax Regs. Class 00.3 specifically excludes "buildings".
Therefore, the Tobacco Barn does not have a 15-year recovery
period by virtue of being includable in class 00.3. Petitioners
have not asserted that the Tobacco Barn is 10-year or 15-year
property by virtue of being includable in any other class of
assets. We therefore sustain respondent on this issue.
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