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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 the
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