109 T.C. No. 2
UNITED STATES TAX COURT
HOSPITAL CORPORATION OF AMERICA AND SUBSIDIARIES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 10663-91, 13074-91, Filed July 24, 1997.
28588-91, 6351-92.
Ps own, operate, and manage hospitals and related
businesses. For taxable years ended 1985 through 1987
Ps claimed depreciation deductions based on 5-year
recovery periods for certain properties they placed in
service during those years, which properties Ps claim
constitute tangible personal property. R determined
that the properties constitute structural components of
the buildings to which they relate and that the
properties therefore must be depreciated over the same
recovery periods as those buildings.
Held: For purposes of assigning appropriate
recovery classes or recovery periods to the properties
to determine allowable depreciation deductions pursuant
to sec. 168, I.R.C., tests developed under prior law
for purposes of the investment tax credit are
applicable to decide whether the property constitutes
tangible personal property.
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