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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 the
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