- 12 - makers, it is petitioners’ understanding that the industry has treated trellising and drip irrigation systems as equipment depreciable over 7 to 10 years. In Sonoma County, California, grapevines become subject to property tax 4 years after planting, whereas trellises, stakes, and irrigation systems are subject to such tax beginning in the year of installation. Discussion The parties disagree about whether trellising, irrigation systems, or a well are to be classified as machinery or land improvements for purposes of depreciation. A depreciation deduction is allowed for the exhaustion, wear and tear, and obsolescence of property used in a trade or business. Sec. 167(a).1 To some extent, the recovery period determines the amount of the depreciation deduction. Sec. 168. The recovery period is based on the “class life” of the property. Sec. 168(c), (e). There is no question in this case about whether the subject assets are depreciable. For purposes of this case, “class life” is the asset guideline class in which such property is classified under Rev. Proc. 83-35, 1983-1 C.B. 745, and restated in Rev. Proc. 87-56 to 1 Unless otherwise specified, section references are to the Internal Revenue Code as amended and in effect for the years under consideration. Rule references are to this Court’s Rules of Practice and Procedure.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007