CCA 200914062: Smart meters and smart grids belong in asset class 49.14

Number
200914062
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Classification of Property
Code sections
§ 168
Ruling dated
March 10, 2009
Publicly released
April 3, 2009

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This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel was asked how to classify utility smart meters and smart grids for tax depreciation purposes. The advice points to the legislative history of sections 168(e)(3)(D)(iii) and (iv). It concludes that asset class 49.14 is the appropriate classification. The short email does not provide further facts or analysis.

Ruling snapshot

  • Question: Which depreciation asset class applies to utility smart meters and smart grids?
  • Outcome: Advice given: the appropriate classification is asset class 49.14.
  • Key authorities: IRC § 168(e)(3)(D)(iii)-(iv).

Full text (IRS public release)

ID: CCA_2009031013235557 Number: 200914062
Release Date: 4/3/2009
Office: ----------------
UILC: 168.20-00

From: ------------------
Sent: Tuesday, March 10, 2009 1:23:58 PM
To: ---------------
Cc: --------------------------------------------------------------
Subject: RE: Utilities: Smartmeters and Smartgrids

The legislative history of sections 168(e)(3)(D)(iii) and (iv) implies that the appropriate
asset class is 49.14.

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