Clajon Gas Co., L.P., Aquila Gas Pipeline Corp., Tax Matters Partner - Page 10




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               Property within Asset Class 13.2 (13.2) is assigned a class            
          life of 14 years and has a recovery period of 7 years; property             
          within Asset Class 46.0 (46.0) is assigned a class life of                  
          22 years and has a recovery period of 15 years.  Rev. Proc. 87-             
          56, 1987-2 C.B. at 678, 684.4                                               
          III.  Class Lives Are Composite Lives                                       
               Historical material pertaining to the ADR system establishes           
          that the class lives contemplated in section 1.167(a)-                      
          11(b)(4)(ii), Income Tax Regs., and established by Rev. Proc. 87-           
          56, supra, and preceding revenue procedures, are composite lives.           
          In other words, each class life is based on the useful lives of             
          the assets constituting the class but does not necessarily equal            
          the useful life of any constituent asset.                                   
               In June 1971, contemporaneous with the adoption of section             
          1.167(a)-11, Income Tax Regs., by T.D. 7128, 1971-2 C.B. 132, the           
          Department of the Treasury published “Asset Depreciation Range              
          (ADR) System” (U.S. Government Printing Office: 1971 O-428-904)             
          (hereafter referred to as Treasury Publication or T.P.).  The               
          Treasury Publication states that, in 1962, with the publication             


               4  The recovery periods assigned to property within 13.2 and           
          46.0 are in accordance with sec. 168(c)(1) and (e)(1), which,               
          together, provide that the recovery period for property with a              
          class life of 10 or more years but less than 16 years is 7 years,           
          and the recovery period for property with a class life of 20 or             
          more years but less than 25 years is 15 years.                              







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