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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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