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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 the
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