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the asset category takes priority over the activity category.
See Norwest Corp. v. Commissioner, supra at 162-164. Any depre-
ciable asset which does not have a class life is classified as 7-
year property and has a recovery period of 7 years. See sec.
168(e)(3)(C)(ii); Rev. Proc. 87-56, supra at 687.
Petitioners contend on brief that the useful life of each of
the aircraft parts in question is less than 4 years and that
therefore they are entitled to depreciate those parts over a 3-
year recovery period. The useful life of a particular asset is
not controlling in determining the applicable recovery period
under section 168.4 In any event, on the record before us, we
find that petitioners have failed to establish that the useful
life of each of the aircraft parts in question is less than 4
years. We further find on that record that petitioners have
failed to establish that the class life of the aircraft parts in
question is 4 years or less.
Based on our examination of the entire record in this case,
we find that petitioners have failed to satisfy their burden of
showing error in respondent’s determination, as modified on brief
4Sec. 168 was enacted into the Code by the Economic Recovery
Tax Act of 1981, Pub. L. 97-34, sec. 201, 95 Stat. 172. One of
the purposes of sec. 168 was to simplify the depreciation rules
by eliminating the need to adjudicate matters such as useful
life, a concept which is inherently uncertain and results in
disagreements between taxpayers and the Internal Revenue Service.
See Simon v. Commissioner, 68 F.3d 41, 45 (1995) (citing S. Rept.
97-144 at 47 (1981), 1981-2 C.B. 412, 425), affg. 103 T.C. 247
(1994).
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