T.C. Memo. 1996-374
UNITED STATES TAX COURT
WALGREEN CO. & SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 6634-92. Filed August 13, 1996.
P, engaged in the retail pharmacy and restaurant
business, made substantial improvements to certain leased
premises. The leasehold improvements constituted property
described in sec. 1250, I.R.C., which P seeks to depreciate
under asset depreciation range Class 57.0, Distributive
Trades and Services, prescribed in Rev. Proc. 83-35, 1983-1
C.B. 745, 762, and R seeks to include under Class 65.0,
Building Services, Rev. Proc. 72-10, 1972-1 C.B. 721, 730.
On the facts, Held: P's leasehold improvements allocated
between Building Services and Distributive Trades and
Services. Walgreen Co. & Subs. v. Commissioner, 68 F.3d
1006 (7th Cir. 1995), revg. and remanding 103 T.C. 582
(1994), applied.
_____________________
*This opinion supplements our previously filed opinion in
Walgreen Co. & Subs. v. Commissioner, 103 T.C. 582 (1994), revd.
and remanded 68 F.3d 1006 (7th Cir. 1995).
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