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(replacement of horizontal elements of a boiler prolonged its
life and permitted commencement of a new 20-plus-year repair
cycle); Ruane v. Commissioner, supra. In light of the facts of
this case, we find that replacing the cell linings cannot be
classified as an incidental repair, and the cost must therefore
be capitalized. See Camilla Cotton Oil Co. v. Commissioner, 31
T.C. 560 (1958); Ruane v. Commissioner, supra; Electric Energy,
Inc. v. United States, supra.
The Cell Room Floors
Between 1991 and 1995, Vanalco replaced the brick floors
of the tap end and center sections of all its cell rooms with
Fondag cement. In 1992, Vanalco replaced the brick floors of the
tap end area of cell room 20, the center areas of cell rooms 10,
12, 14, and 18, and the tap end and center areas of cell rooms 16
and 22. In 1993, Vanalco replaced the brick floors of the tap
end areas of cell rooms 8 and 10, and the tap end and center
areas of cell rooms 14 and 18. The substantial nature of the
replacements during the years at issue tends to prove that they
were more than incidental repairs. See Stark v. Commissioner,
T.C. Memo. 1999-1.
The parties have stipulated that the replaced areas of the
floors were the areas that were subjected to the most mechanical
equipment traffic and that the replacements were due, in part, to
the introduction of the mechanical equipment. Repairs to the
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