- 6 - 1. Interior partitions, including primarily drywall partitions, but also including some glass partitions in Walgreen drugstores and metal partitions in washrooms, and including the carpentry, framing, millwork, metalwork, and trimwork necessary for installation, and also including doors; 2. ceilings, including the acoustic ceiling system consisting of panels and grid, and also including some drywall ceilings; 3. electrical lighting fixtures, including recessed and lay-in lighting, beyond emergency lighting, night lighting, and exit lighting, and the branch circuit systems and power system relating thereto; 4. interior floor finishes, including carpet, vinyl or rubber tile, ceramic and quarry tile, and epoxy or sealers; and, 5. decor finishes, primarily the decorative canopy system relating to the Wag's restaurants, including the concrete foundation, concrete piers, lumber, and signs attached thereto. In its opinion, the Court of Appeals noted that the parties agree that any asset that might be included in both "Wholesale and Retail Trade" and "Building Services" would be classified in Building Services. Walgreen Co. & Subs. v. Commissioner, 68 F.3d at 1008. In complying with the Mandate of the Court of Appeals to fit a legal definition to the facts of this case, we find that, though items in categories 1 through 4, supra, mightPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011