- 23 - included in any asset guideline class must be based upon the “class life prescribed by the Secretary which reasonably reflects the anticipated useful life of that class of property to the industry or other group.” (Emphasis added.) Such an approach is also consistent with Treasury’s description of section 1.167(a)- 11, Income Tax Regs., as, essentially, an extension of the composite class life system adopted in Rev. Proc. 62-21, 1962-2 C.B. 418. See supra sec. III. (2) Asset Class 13.2 Asset guideline class 13.2 describes property, including gathering pipelines, used by natural gas producers. Since, however, we have found that petitioner is not a natural gas producer, its gathering pipelines are not 13.2 property. Given the composite nature of class lives, that is an appropriate result. If a taxpayer is not engaged in the activity described in an asset guideline class, then the associated class life is not representative of the life of any class of business assets owned by him. Only by coincidence would the class life be the useful life of any asset owned by the taxpayer. To permit such a taxpayer to depreciate a particular asset or type of asset on the basis of a composite class life designed for a completely different group of taxpayers utilizing a completely different mix of assets would be to frustrate the overall intent and design of the class life system adopted by Congress and implemented by thePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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