Walgreen Co. & Subsidiaries - Page 6

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               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, might                  





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