SECTION 6. UNITS OF PROPERTY

FOR WIRELESS NETWORK ASSETS

.01 In general . For wireless 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) the MTSO building (including its structural components) constitutes a single unit of property;

(B) all of the MTSO equipment constitutes a single unit of property;

(C) all cell site transmission equipment at a cell site constitutes a single unit of property;

(D) all cell site radio equipment at a cell site constitutes a single unit of property;

(E) all cell site support equipment at a cell site constitutes a single unit of property;

(F) the antenna support structure (also known as a tower) affixed to a foundation (for example, a concrete foundation, a building rooftop, or a building wall) at a cell site constitutes a single unit of property;

(G) the concrete foundation upon which the antenna support structure is installed, including the bolts embedded therein and other depreciable assets associated with the platform or other forms of anchoring to affix a tower to a foundation, constitutes a single unit of property;

(H) the cell site enclosure (hut) and the cement slab or foundation upon which the hut is installed constitute a single unit of property; and

(I) all depreciable land improvements at a cell site constitute a single unit of property. Depreciable land improvements include landscaping that is replaced when a related depreciable asset is replaced, fences, and sidewalks, but exclude enclosures or buildings suitable for occupation and any improvements properly capitalized to the land.

.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 similar assets, including similar wireless 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 clas

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of accounting or (b) all, or some, of the units of property described in Rev. Proc. 2011–28. (2) Waiver of scope limitations . The scope limitations in section 4.02 of this revenue procedure do not apply to a wireless telecommunications carrier that changes to a method of accounting provided in section 5 or section 6 of Rev. Proc. 2011–28 for its first or second taxable year ending after December 30, 2010.

(3) Section 481(a) adjustment . In general, a change to the wireless network asset maintenance allowance method of accounting or adoption of all, or some, of the units of property specified in Rev. Proc. 2011–28 requires an adjustment under § 481(a). The § 481(a) adjustment shall not include any amount attributable to property for which the taxpayer elected to apply the repair allowance under § 1.167(a)–11(d)(2).

(4) Ogden copy of Form 3115 required in lieu of national office copy . A taxpayer changing its method of accounting under section 3.08 of the APPENDIX must file a signed copy of its completed Form 3115 with the IRS in Ogden, UT, (Ogden copy) in lieu of filing the national office copy no earlier than the first day of the year of change and no later than the date the taxpayer files the original Form 3115 with its federal income tax return for the year of change. See sections 6.02(3)(a)(ii)(B) (providing the general rules) and section 6.02(7)(b) (providing the mailing address) of this revenue procedure.

(5) Designated automatic accounting method change numbers . The designated automatic accounting method change number for a change to the method of accounting provided in Rev. Proc. 2011–28 is “159.”

(6) Contact information . For further information regarding a change under this section, contact Alan S. Williams at (202) 622–4950 (not a toll-free call).