Clajon Gas Co., L.P., Aquila Gas Pipeline Corp., Tax Matters Partner - Page 12

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          used by businesses generally (e.g., trucks and railroad cars),              
          generally classified assets by business activity.                           
               The Treasury Publication describes the ADR and class life              
          system then being established by Treasury decision (T.D. 7128,              
          1971-2 C.B. 132, adopting section 1.167(a)-11, Income Tax Regs.)            
          as, essentially, an extension and modification of the asset                 
          guideline class approach taken in Rev. Proc. 62-21.  T.P. 212-              
          219.  The Treasury Publication describes adoption of the new                
          system as being prompted, in part, by (1) recognition that it had           
          been more than 7 years since there had been any significant                 
          changes in the guidelines classes or lives, and (2) requests from           
          members of Congress that Treasury study the adequacy of the then            
          existing depreciation allowances.  Id. at 215, 217-218.                     
               Reflecting the approach that had been taken in Rev. Proc.              
          62-21, supra, and section 1.167-11, Income Tax Regs., Congress,             
          in section 167(m)(1), provided that, for each class of property,            
          the Secretary must prescribe a class life that reflects the                 
          anticipated useful life of that class of property “to the                   
          industry or other group.”  Pursuant to that mandate, the                    
          Secretary had the authority to, and did, subdivide industries,              
          establishing asset guideline classes inclusive of one or more               
          sectors of the industry and exclusive of others.  Thus, the same            
          asset used in more than one sector of an industry might be                  

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