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(b) General Transitional Rule.--
* * * * * * *
(2) Requirement that certain property be placed in
service before certain date.--
(A) In General.--Paragraph (1) and section
204(a) * * * [which includes the supply and service
contracts exception] shall not apply to any property
unless such property has a class life of 7 years and is
placed in service before the applicable date determined
under the following table:
In the case of property with a class life of: The
applicable date is:
At least 7 but less than 20 years January 1, 1989
20 years or more January 1, 1991
* * * * * * *
(C) Class Lives.--
* * * * * * *
(ii) property described in section 204(a)
shall be treated as having a class life of 20
years. * * *
At first blush, there appears to be an inconsistency between the
requirement in subsection (b)(2)(A), which requires that TRA
section 204(a) property have a class life of at least 7 years,
and subsection (b)(2)(C)(ii), which provides that TRA section
204(a) property shall be treated as having a class life of 20
years.
The parties agree that the nuclear fuel assemblies have a
class life of 5 years under Rev. Rul. 87-56, 1987-2 C.B. 674, and
that petitioner treated these assemblies as having a class life
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