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C.B. 721, as setting forth the applicable “asset guideline
classes”. Rev. Proc. 72-10 was the first of several revenue
procedures establishing asset guideline classes, each superseding
or obsoleting its predecessor and culminating in Rev. Proc. 87-
56, 1987-2 C.B. 674.3 Rev. Proc. 87-56 is the revenue procedure
establishing asset guideline classes that is in effect for
purposes of this case.
The Rev. Proc. 87-56 asset guideline classes at issue in
this case are as follows:
[Asset Class] 13.2 Exploration for and Production of
Petroleum and Natural Gas Deposits: Includes assets
used by petroleum and natural gas producers for
drilling of wells and production of petroleum and
natural gas, including gathering pipelines and related
storage facilities. Also includes petroleum and
natural gas offshore transportation facilities used by
producers and others consisting of platforms (other
than drilling platforms classified in Class 13.0),
compression or pumping equipment, and gathering and
transmission lines to the first onshore transshipment
facility. * * *
* * * * * * *
[Asset Class] 46.0 Pipeline Transportation: Includes
assets used in the private, commercial, and contract
carrying of petroleum, gas and other products by means
of pipes and conveyors. The trunk lines and related
storage facilities of integrated petroleum and natural
gas producers are included in this class. * * *
3 Rev. Proc. 87-56, 1987-2 C.B. 674, was issued to take
into account amendments made to sec. 168 as part of the Tax
Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2121.
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