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1986, under subsection (m) of section 167”.1 Section 167(m)(1),
in pertinent part, provided for depreciation “based on the class
life prescribed by the Secretary which reasonably reflects the
anticipated useful life of that class of property to the industry
or other group.” Section 167(m) (which was added to the Internal
Revenue Code by section 109 of the Revenue Act of 1971, Pub. L.
92-178, 85 Stat. 508) codified, with certain modifications, the
Asset Depreciation Range (ADR) system described in section
1.167(a)-11, Income Tax Regs., and, in particular, the
regulations’ adoption of asset guideline classes and periods or
“class lives”.2 See H. Rept. 92-533, 1972-1 C.B. 498, 514-516;
S. Rept. 92-437, 1972-1 C.B. 559, 584-588.
Consistent with the directive in section 167(m)(1) to
prescribe class lives for depreciable assets, section 1.167(a)-
11(b)(4)(ii), Income Tax Regs., provides that asset guideline
classes and periods (lives) will be “established, supplemented,
and revised * * *, and will be published in the Internal Revenue
Bulletin.” The regulation references Rev. Proc. 72-10, 1972-1
1 Sec. 167(m) was deleted from the Internal Revenue Code by
the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508,
sec. 11812(a)(1), 104 Stat. 1388-534.
2 A notice of proposed rulemaking was published in the
Federal Register on Mar. 13, 1971, 36 F.R. 4885, and a Treasury
Decision setting forth final regulations was published in the
Federal Register on June 23, 1971, 36 F.R. 11924. See T.D. 7128,
1971-2 C.B. 132. The final regulations were subsequently
modified, in 1973, to conform the ADR system to sec. 167(m). See
T.D. 7272, 1973-1 C.B. 82.
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