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Pursuant to information received from the Federal Communications Commission , we added a provision to subsection ( a ) ( 3 ) of the proposed rule , excluding from the assessment revenue private carrier paging services until August 10 , 1996 . In this case , because the work was piecemeal , took place over lengthy periods of time , and the system continued to fulfill its function , the Tax Division argued that the labor to replace the transmission systems was labor to upgrade the systems and taxable . Because the book value of the taxpayer 's net assets prior to the acquisition exceeded the cost allocable to those assets , the taxpayer reduced the book value of the non-current assets after the acquisition . I think it would really fly in the face of our position in the sense that we've challenged her report . The attorney expressed his concerns that the amended definitions will set stricter standards for organizations to qualify for exemption .