- 24 - regulations and by Rev. Proc. 87-56, supra. Petitioner is not a gas producer and, therefore, has no claim on 13.2. The point is aptly illustrated by the treatment of drilling equipment under Rev. Proc. 87-56, supra. Asset class 13.1 (13.1), entitled “Drilling of Oil and Gas Wells”, provides a 6-year class life and 5-year recovery period for “assets used in the drilling of onshore oil and gas wells”, e.g., an oil or gas drilling rig. The same assets “used by petroleum and natural gas producers” fall within 13.2, which, as noted above, provides a 14-year class life and 7-year recovery period. Just as a drilling rig may have two different class lives and recovery periods, depending upon the asset class within which it is includable, so too may gathering pipelines be subject to different class lives and recovery periods depending upon the user and the asset class appropriate to that user. (3) Asset Class 46.0 Petitioner argues that 46.0 is intended to encompass only transmission pipelines. In support of its argument, petitioner states that, within the natural gas industry, “the term ‘transportation pipeline’ is synonymous with ‘transmission pipeline’”, and that the Federal Energy Regulatory Commission (FERC) distinguishes between gathering, over which it lacks jurisdiction, and the interstate transportation of natural gas, over which it has jurisdiction, a distinction upon which thePage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011