
How is the class life determined for carpeting in a commercial office building for Section 179(d)(5)(B) purposes?
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To determine the class life for carpeting in a commercial office building for purposes of Section 179(d)(5)(B), you must follow the rules for classifying property under the MACRS system, which relies on the class life system as set forth in Rev. Proc. 87-56 and as referenced in the Internal Revenue Code and Treasury Regulations.
Step 1: Identify the Asset and Its Use
- The asset in question is carpeting.
- The context is a commercial office building (i.e., nonresidential real property).
Step 2: Locate the Asset in the Class Life Tables
- Under Rev. Proc. 87-56, as incorporated into IRS Publication 946 and the Cost Segregation Audit Technique Guide, assets are classified first by specific asset categories (asset classes 00.11 through 00.4), and if not found there, by activity categories (asset classes 01.1 through 80.0).
- For carpeting, the relevant asset class is 00.11, "Office Furniture, Fixtures, and Equipment," which includes furniture and fixtures that are not a structural component of a building, such as desks, files, safes, and communications equipment. Carpeting is generally considered a fixture and is included in this asset class.
- The IRS Cost Segregation Audit Technique Guide and industry-specific IRS guidance (e.g., for retail, restaurant, and office buildings) consistently classify carpeting as a fixture, not a structural component, and assign it to asset class 00.11.
Step 3: Determine the Class Life
- Asset class 00.11, "Office Furniture, Fixtures, and Equipment," has a class life of 10 years.
- This is confirmed in Table B-1 of IRS Publication 946, which lists "Office Furniture, Fixtures, and Equipment" as having a 10-year class life.
Step 4: Application to Section 179(d)(5)(B)
- The class life for carpeting, as a fixture in a commercial office building, is therefore 10 years.
Step 5: Special Note on Recovery Period
- While the class life is 10 years, the MACRS recovery period for such property is 7 years under the General Depreciation System (GDS), but for Section 179(d)(5)(B) purposes, it is the class life (not the MACRS recovery period) that is relevant.
Summary Table
Conclusion
For Section 179(d)(5)(B) purposes, the class life of carpeting installed in a commercial office building is 10 years, as determined by asset class 00.11 under Rev. Proc. 87-56 and as referenced in section 168(i)(1).
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