- 10 - petitioner reclassify each item of the Equipment in accordance with MACRS, alternative depreciation system rules, as required under section 168(g)(1)(A). Such reclassification resulted in a change in depreciation method and recovery period. Even though petitioner concedes that the reclassification is correct, it argues that, under the rationale explicated in Brookshire Bros. Holding, Inc. & Subs. v. Commissioner, supra, a reclassification of property under MACRS is to be treated as synonymous with an adjustment in useful life for purposes of a regulatory exception contained in section 1.446-1(e)(2)(ii)(b), Income Tax Regs. Respondent argues that for purposes of section 1.446- 1(e)(2)(ii), Income Tax Regs., as interpreted by the Commissioner, the term “useful life” is not synonymous with the term “recovery period.” Respondent cites Thomas Jefferson Univ. v. Shalala, 512 U.S. 504 (1994), for the propositions that this Court should “give substantial deference to an agency’s interpretation of its own regulations”, and “must defer to an agency’s interpretation unless an alternative reading is compelled by the regulation’s plain language or by other indications of the agency’s intent at the time the regulation is promulgated.” The weight accorded to an agency’s interpretation depends on the thoroughness of the agency’s consideration, validity of its reasoning, consistency with earlier and later pronouncements, and other factors that give an interpretation thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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