SECTION 6. UNITS OF PROPERTY

FOR WIRELINE NETWORK ASSETS

.01 In general. For wireline network assets, the Service will not challenge any of the following unit of property determinations for purposes of the application of § 263(a) and the regulations thereunder:

(A) all the towers and poles, and all the structures and fittings mounted on towers and poles, (“fully-dressed poles”) in a wire center constitute a single unit of property;

(B) all the copper wire and any associated devices, whether overhead or underground, in a wire center constitute a single unit of property;

(C) all the fiber optic cable and any associated devices, whether overhead or underground, in a wire center constitute a single unit of property;

(D) all the underground conduit and ducts, as well as controlled environmental vaults (“CEVs”), manholes, and handholes, in a wire center constitute a single unit of property;

(E) each central office building (including its structural components) constitutes a single unit of property;

(F) all central office equipment associated with a central office building constitutes a single unit of property;

(G) all SAI boxes in a wire center constitute a single unit of property; and

(H) all RNTs in a wire center constitute a single unit of property.

.02 Universal adoption not required . A taxpayer within the scope of this revenue procedure is not required to adopt all of the unit of property determinations provided in section 6.01 of this revenue procedure and, therefore, may adopt one or more of the unit of property determinations provided. Once adopted, however, a unit of property determination applies to all sim

ilar assets, including similar wireline network assets acquired in an applicable asset acquisition as defined in § 1060 or in a transaction to which § 338(h)(10) applies.

.03 Limitation . The unit of property determinations provided in this revenue procedure shall not apply for any other purpose of the Code or Regulations, including for determining the unit of property under other Code sections (for example, § 263A), or determining the asset for depreciation purposes (including placed in service, retirements, dispositions, or classification under § 168(e) or Rev. Proc. 87–56, 1987–2 C.B. 674), for the same or similar type of assets used in wireline telecommunications or other industries.