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the terms in petitioner’s typical Service Rental Agreement to
support the redetermination of the useful life.
Based on the evidence and the facts known to petitioner’s
management during the years in issue, we are persuaded that
petitioner did make a reasonable approximation of the useful life
of the garments and dust control items and that the approximation
was based on a reasonable relation to its business practice. The
following factors support petitioner’s approximation of the
useful life of its garments and dust control items: (1) The
placing of garments and dust control items in service was a
common and frequent event in petitioner’s business; (2) the value
of the garments became negligible when placed in service because
the garments were, generally, custom designed, measured to fit
customers’ employees, and marked with a company’s name or logo;
(3) the removal of garments and dust control items from service
was a continuous process in petitioner’s business; (4) garments
and dust control items were withdrawn from service for various
physical reasons; (5) industrial garments were subject to
continual wear and tear from the harsh and hazardous environments
in which they were worn and from the laundering process;
(6) clean room garments were withdrawn from service if, through
wear and tear, defect, or damage, they no longer met a customer’s
strict quality control requirements; (7) garments and dust
control items were withdrawn from service for reasons not related
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