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of Rev. Proc. 62-21, 1962-2 C.B. 418, the Treasury introduced a
fundamental change in the concept of depreciation. T.P. at 212-
213. The fundamental change was to classify assets on a basis
other than the particular life of the particular asset to the
particular user. Id. at 215. On the new basis, assets were
classified “as a stock of capital even though assets within a
class were heterogeneous with respect to ages, useful lives, and
physical characteristics.” Id. “Assets within the class would
have individual lives far longer and far shorter than the
guideline class life.” Id. at 215-216. The Treasury Publication
describes Rev. Proc. 62-21 as providing a substitute for the
thousands of asset classifications of the previous system. Id.
at 212-213. Under Rev. Proc. 62-21, “assets were grouped by
broad industrial classifications and by certain broad general
asset classifications, with a ‘guideline life’ established for
each of these classes.” Id. at 213. An examination of the asset
guideline classes in Rev. Proc. 62-21 discloses that, generally,
the classes are tied to particular business activities. The
drafters of the revenue procedure recognized that the anticipated
useful life of many assets, even the same types of assets, will
vary in accordance with the experience of persons using such
assets. The drafters assumed that persons in the same business
activity would have similar experiences and, except for assets
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