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to exhaustion of their physical life such as obsolescence,
contract cancellations or terminations, employee turnover, change
in an employee’s size, and customer design changes; and
(8) garments and dust control items that were removed from
service for reasons other than physical damage were difficult to
reuse in petitioner’s business.
Respondent maintains that petitioner has produced no
quantifiable evidence and has had several years to document the
correctness of its approximations. Respondent argues:
(1) Petitioner had sufficient time to produce its own study that
would determine the useful life of the garments and dust control
items and should not rely on industry experience, (2) petitioner
labeled its garments and maintained a garment tracking system and
should be able to document the useful life of the garments placed
in service without an additional record keeping burden,
(3) petitioner had test laboratories in which to perform tests to
determine the useful life of the garments and dust control items,
(4) petitioner represented to its customers in the years
subsequent to the years in service that certain clean room
garments could have a service life of up to 4 years, and (5) the
life of the 65-percent polyester and 35-percent cotton garments
was longer than the life of the 100-percent cotton garments used
in 1968.
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