PDV America, Inc. and Subsidiaries - Page 2

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          Docket No. 12124-02                                                         
               Year      Deficiency                                                   
               1996      $119,774                                                     
          Docket No. 12125-02                                                         
               Year      Deficiency                                                   
               1997      $218,170                                                     
          Petitioners timely filed petitions contesting respondent’s                  
          determinations.  Upon motion of the parties, these cases were               
          consolidated for purposes of trial, briefing, and opinion.                  
               After concessions,1 the issue for decision is whether                  
          certain aboveground storage tanks located at petitioners’ refined           
          product terminals are included in Modified Asset Cost Recovery              


               1Respondent conceded that the following aboveground storage            
          tanks are included in Modified Asset Cost Recovery System (MACRS)           
          Asset Guideline Class 57.0, Rev. Proc. 87-56, 1987-2 C.B. 674,              
          686:                                                                        
               Terminal location                         Tank No.                     
                                                                                     
               Albany, N.Y.                            51                             
               Brownsville, Tex.                            5                         
               Milwaukee, Wis.                         8, 9                           
               Mt. Prospect, Ill.                      10, 11, 12                     
               Niceville, Fla.                              3                         
               San Antonio, Tex.                  104, 105, 106, 107, 111             
               Spartanburg, S.C.                            7                         
               Vestal, N.Y.                                 6                         
          These tanks had shell capacities of 5,000 barrels or less,                  
          heights of 35 feet or less, and diameters of 35 feet or less.               
               In addition, the parties agree that the class lives for the            
          Pittsburgh, Pa., terminal’s tanks at issue will be the same as              
          the class life determined with respect to tank No. 1 at the                 
          Chesapeake, Va., terminal.                                                  




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