Mark and Helen Thomson - Page 7




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          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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