- 7 -
1990, Pub. L. 101-508, sec. 11812(a), 104 Stat. 1388, 1388-534
(former section 167(m)). Former section 167(m) permitted depre-
ciation deductions to be determined with respect to a depreciable
asset on the basis of a class life prescribed for such asset by
the Secretary of the Treasury or his delegate (Treasury). The
class lives prescribed by the Treasury for various depreciable
assets are found in a series of revenue procedures issued by the
Commissioner of Internal Revenue. See sec. 1.167(a)-
11(b)(4)(ii), Income Tax Regs. The revenue procedure in effect
for the years at issue is Rev. Proc. 87-56, 1987-2 C.B. 674, as
clarified and modified by Rev. Proc. 88-22, 1988-1 C.B. 785 (Rev.
Proc. 87-56).
Rev. Proc. 87-56 divides depreciable assets into two broad
categories: (1) Asset guideline classes (asset classes) 00.11
through 00.4, consisting of specific depreciable assets used in
all business activities (the asset category), and (2) asset
classes 01.1 through 80.0, consisting of depreciable assets used
in specific business activities (the activity category). See
Rev. Proc. 87-56, 1987-2 C.B. at 676-687. The same item of
depreciable property may be listed in both the asset category and
the activity category. See, e.g., Rev. Proc. 87-56, supra at
681; see also Norwest Corp. v. Commissioner, 111 T.C. 105, 159
(1998). In the event that a depreciable asset is listed in Rev.
Proc. 87-56 in both the asset category and the activity category,
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