Rev. Proc. 87-56

1987-2 C.B. 674

Section 168 -- ACRS Depreciation

Statement of Procedural Rules

Modified by Rev. Proc. 88-22

Clarified by Rev. Proc. 88-22

Summary

SERVICE PROVIDES CLASS LIVES FOR DEPRECIATION PURPOSES.

The Service has issued Rev. Proc. 87-56, providing class lives of property that are necessary to compute the depreciation allowances available under section 168, as amended by section 201(a) of the Tax Reform Act of 1986. The guidance applies to both the general depreciation system under section 168(a) and the alternative depreciation system (ACRS) provided in section 168(g).

For further information on Rev. Proc. 87-56, call Rick Robbins at (202) 566-4440. Rev. Proc. 83-35 was made obsolete by Rev. Proc. 87-56.

Full Text

Rev. Proc. 87-56

SECTION 1. PURPOSE

The purpose of this revenue procedure is to set forth the class lives of property that are necessary to compute the depreciation allowances available under section 168 of the Internal Revenue Code, as amended by section 201(a) of the Tax Reform Act of 1986 (Act), 1986-3 (Vol. 1) C.B. 38. Rev. Proc. 87-57, page 17, this Bulletin, describes the applicable depreciation methods, applicable recovery periods, and applicable conventions that must be used in computing depreciation allowances under section 168.

SEC. 2. GENERAL RULES OF APPLICATION

01 IN GENERAL. This revenue procedure specifies class lives and recovery periods for property subject to depreciation under the general depreciation system provided in section 168(a) of the Code or the alternative depreciation system provided in section 168(g).

02 DEFINITION OF CLASS LIFE. Except with respect to certain assigned property described in section 3 of this revenue procedure, for purposes of both the general depreciation system and the alternative depreciation system, the term "class life" means the class life that would be applicable for any property as of January 1, 1986, under section 167(m) of the Code (determined without regard to paragraph 4 thereof and determined as if the taxpayer had made an election under section 167(m)). The class life that would be applicable for any property as of January 1, 1986, under section 167(m), is the asset guideline period (midpoint class life) for the asset guideline class in which such property is classified under Rev. Proc. 83-35, 1983-1 C.B. 745. However, for purposes of the alternative depreciation system, section 168(g)(3)(B) assigns a class life to certain property that is taken into account under section 168 rather than the class life that would be applicable as of January 1, 1986. The class life of property that is either determined as of January 1, 1986, under Rev. Proc. 83-35 or assigned under section 168(g)(3)(B) may be modified by the Secretary pursuant to authority granted under section 168(i)(1). See section 4 of this revenue procedure.

03 REV. PROC. 83-35. Rev. Proc. 83-35 sets out the asset guideline classes, asset guideline periods and ranges, and annual asset guideline repair allowance percentages for the Class Life Asset Depreciation Range System. The asset guideline periods (midpoint class lives) set out in Rev. Proc. 83-35 are also used in defining the classes of recovery property under the Accelerated Cost Recovery System (that is, section 168 of the Code as in effect prior to amendment by section 201 of the Act). Rev. Proc. 83-35 remains effective for property subject to depreciation under those systems. Rev. Proc. 83-35 does not apply to property subject to depreciation under section 168, other than as a basis for determining the class lives of such property under section 2.02 of this revenue procedure.

04 PROPERTY WITH NO CLASS LIFE. Property that is neither described in an asset guideline class listed in section 5 of this revenue procedure nor assigned a class life under section 168(g)(3)(B) of the Code is treated as property having no class life for purposes of section 168 unless and until a class life is prescribed by the Secretary pursuant to the authority granted under section 168(i)(1). See section 4 of this revenue procedure. The general and alternative depreciation systems contain separate rules for classifying property that does not have a class life.

SEC. 3. ASSIGNED PROPERTY WITH ASSIGNED CLASS LIVES, RECOVERY CLASSES, OR RECOVERY PERIODS

Under section 168(i)(1)(E) of the Code, the term "assigned property" means property for which a class life, recovery class, or recovery period is assigned under section 168(e)(3) or section 168(g)(3)(B), (C), or (D), and the term "assigned item" means the class life, recovery class, or recovery period assigned under section 168(e)(3) or section 168(g)(3)(B), (C), or (D). For purposes of the general depreciation system assigned property under section 168(c)(3) is assigned to a recovery class without regard to such property's class life. (See section 3.02 of Rev. Proc. 87-57, this Bulletin.) For purposes of the alternative depreciation system, certain assigned property is assigned a class life under section 168(g)(3)(B), notwithstanding such property's class life as set out in Rev. Proc. 83-35. See section 3.03 of Rev. Proc. 87-57, this Bulletin. For purposes of the alternative depreciation system, certain assigned property is assigned a recovery period under section 168(g)(3)(C), (D), or (E), notwithstanding such property's class life (if any).

SEC. 4. PRESCRIPTION AND MODIFICATION OF CLASS LIVES

01 Section 168(i)(1)(B) of the Code provides that the Secretary, through an office established in the Treasury, shall monitor and analyze actual experience with respect to all depreciable assets. Except in the case of section 1250 property that is residential rental property or nonresidential real property, the Secretary, through that office, (i) may prescribe a new class life for any property, (ii) in the case of assigned property, may modify any assigned item, or (iii) may prescribe a class life for any property that does not have a class life within the meaning of section 2.02 of this revenue procedure. Any class life or assigned item that is prescribed or modified pursuant to this authority shall be used for all purposes in determining depreciation allowances under the general depreciation system and the alternative depreciation system. In the case of assigned property as defined in section 168(i)(1)(E), no class life set forth in this revenue procedure nor any other assigned item may be modified, unless such modification reflects a shortening of such class life, for property placed in service prior to January 1, 1992.

02 Prescription or modification of class lives under the authority granted in section 168(i)(1)(B) of the Code shall reflect the anticipated useful lives, and the anticipated decline in value over time (that is, economic depreciation) of an asset to the industry or other group. Rules and practices governing prescription and modification of class lives pursuant to the authority granted in section 168(i)(1)(B) shall be announced through the office referred to in section 4.01 of this revenue procedure.

SEC. 5. TABLES OF CLASS LIVES AND RECOVERY PERIODS

01 Except for property described in section 5.02, below, the class lives (if any) and recovery periods for property subject to depreciation under section 168 of the Code appear in the tables below. These tables are based on the definition of class life in section 2.02 of this revenue procedure and the assigned items described in section 3 of this revenue procedure.

02 For purposes of depreciation under the general depreciation system, residential rental property has a recovery period of 27.5 years and nonresidential real property has a recovery period of 31.5 years. For purposes of the alternative depreciation system, residential rental and nonresidential real property each has a recovery period of 40 years.

03 Generally, the asset classes in the tables are incorporated from the asset guideline classes in Rev. Proc. 83-35 as of January 1, 1986. However, descriptions of the following asset classes have been amended or added: 00.12, 00.3, 01.221, 01.222, 01.3, 01.4, 36.0, 36.1, 40.4, 48.12, 48.121, 48.31-48.45, 50 and 51. Certain asset guideline classes in Rev. Proc. 83-35 included property on the basis of regulated accounts. For purposes of section 168 of the Code and this revenue procedure, asset classes include property described therein without regard to whether a taxpayer is a regulated public utility or an unregulated company.

04 In addition to specifying class lives for each asset guideline class, the tables list certain property for which a recovery period is assigned, notwithstanding such property's class life (if any). See section 3 of this revenue procedure. The listed assigned property classes (denoted A-E) generally do not correspond to asset guideline classes for which class lives are specified in the tables. The class life (if any) of an item of assigned property described in classes A-E is determined by reference to the asset guideline class (if any) containing such item of property. If an item of assigned property described in classes A-E is not contained in any asset guideline class, such item of property has no class life.

EXAMPLES. Qualified technological equipment as defined in section 168(i)(2) (class B) is assigned a recovery period of 5 years for both the general and alternative depreciation systems, notwithstanding such property's class life (if any). Property which is a computer or peripheral equipment, high technology telephone station equipment installed on the customer's premises or high technology medical equipment within the meaning of section 168(i)(2), may be described in asset guideline class 00.12 (class life 6 years), 48.13 (class life 10 years) or 57.0 (class life 9 years), respectively. Property used in connection with research and experimentation referred to in section 168(e)(3)(B) (class C) is assigned a recovery period of 5 years for the general depreciation system, notwithstanding its class life (if any). Such property's recovery period for the alternative depreciation system is based on its class life (if any). An item of property used in connection with research and experimentation has a class life if such property is contained in an asset guideline class.

05 The following special rules are incorporated from Rev. Proc. 83-35, sections 2.02(iii) and (iv):

1. Asset guideline class 00.3, "Land Improvements," includes "other tangible property" that qualifies under section 1.48-1(d) of the Income Tax Regulations. However, a structure that is essentially an item of machinery or equipment or a structure that houses property used as an integral part of an activity specified in section 48(a)(1)(B)(i) of the Code, if the use of the structure is so closely related to the use of the property that the structure clearly can be expected to be replaced when the property it initially houses is replaced, is included in the asset guideline class appropriate to the equipment to which it is related.

2 Asset class 30.11 includes general rebuilding or rehabilitation costs for the special tools defined in class 30.11 that have been traditionally capitalized as the cost of a new asset.

SEC. 6. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 83-35 is obsoleted for property that is subject to section 168 of the Code.

The principal author of this revenue procedure is Mr. Rick Robbins of the Corporation Tax Division. For further information regarding this revenue procedure, contact Mr. Rick Robbins on (202) 566-4440 (not a toll-free call).

Recovery Periods

(in years)

Class General Alternative

Life Depre- Depre-

Asset (in ciation ciation

class Description of assets included years) System System

______

SPECIFIC DEPRECIABLE ASSETS USED IN ALL BUSINESS ACTIVITIES, EXCEPT

AS NOTED:

00.11 OFFICE FURNITURE, FIXTURES

AND EQUIPMENT:

Includes furniture and fixtures that

are not a structural component of a

building. Includes such assets as

desks, files, safes, and

communications equipment. Does not

include communications equipment

that is included in other classes 10 7 10

00.12 INFORMATION SYSTEMS:

Includes computers and their

peripheral equipment used in

administering normal business

transactions and the maintenance of

business records, their retrieval

and analysis.

Information systems are defined as:

1) Computers: A computer is a

programmable electronically

activated device capable of

accepting information, applying

prescribed processes to the

information, and supplying the

results of these processes with or

without human intervention. It

usually consists of a central

processing unit containing extensive

storage, logic, arithmetic, and

control capabilities. Excluded from

this category are adding machines,

electronic desk calculators, etc.

and other equipment described in

class 00.13

2) Peripheral equipment consists of

the auxiliary machines which are

designed to be placed under control

of the central processing unit.

Nonlimiting examples are: Card

readers, card punches, magnetic tape

fees, high speed printers, optical

character readers, tape cassettes,

mass storage units, paper tape

equipment, keypunches, data entry

devices, teleprinters, terminals,

tape drives, disc drives, disc

files, disc packs, visual image

projector tubes, card sorters,

plotters, and collators. Peripheral

equipment may be used on-line or off-

line.

Does not include equipment that is

an integral part of other capital

equipment that is included in other

classes of economic activity, i.e.,

computers used primarily for process

or production control, switching,

channeling, and automating

distributive trades and services

such as point of sale (POS) computer

systems. Also, does not include

equipment of a kind used primarily

for amusement or entertainment of

the user 6 5 /1/ 5 /1/

00.13 DATA HANDLING EQUIPMENT, EXCEPT

COMPUTERS:

Includes only typewriters,

calculators, adding and accounting

machines, copiers, and duplicating

equipment 6 5 6

00.21 AIRPLANES (AIRFRAMES AND ENGINES),

EXCEPT THOSE USED IN COMMERCIAL OR

CONTRACT CARRYING OF PASSENGERS OR

FREIGHT, AND ALL HELICOPTERS

(AIRFRAMES AND ENGINES) 6 5 6

00.22 AUTOMOBILES, TAXIS 3 5 5

00.23 BUSES 9 5 9

00.241 LIGHT GENERAL PURPOSE TRUCKS:

Includes trucks for use over the

road (actual unloaded weight less

than 13,000 pounds) 4 5 5

00.242 HEAVY GENERAL PURPOSE TRUCKS:

Includes heavy general purpose

trucks, concrete ready mix-

truckers, and ore trucks, for use

over the road (actual unloaded

weight 13,000 pounds or more) 6 5 6

00.25 RAILROAD CARS AND LOCOMOTIVES,

EXCEPT THOSE OWNED BY RAILROAD

TRANSPORTATION COMPANIES 15 7 15

00.26 TRACTOR UNITS FOR USE OVER-THE-

ROAD 4 3 4

00.27 TRAILERS AND TRAILER-MOUNTED

CONTAINERS 6 5 6

00.28 VESSELS, BARGES, TUGS, AND SIMILAR

WATER TRANSPORTATION EQUIPMENT,