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All of the property items in issue (disputed property items)
were installed in hospitals constructed for petitioners pursuant
to contracts with general construction contractors during taxable
years ended 1985, 1986, 1987, and 1988. The parties have agreed
as to the proper categorization and the total construction cost
of each facility, the cost bases of the particular disputed
property items,4 and the dates on which each of the facilities
(and the property items located therein) were placed in service.
The parties have agreed to procedures to be followed to implement
our decision once we decide the appropriate recovery classes (or
recovery periods) for the disputed property items.
The parties have designated one facility to serve as a
"representative facility" for each of the 10 different categories
of hospital facilities. The parties agree, however, that the
property items in petitioners' hospital facilities are identical
to each other in all material respects (i.e., manner of
4 For convenience, the parties have assigned various property
unit numbers to the disputed property items. The parties defined
and identified property units to include all functionally or
structurally related items. Property units are categorized as
either item property units or group or system property units.
From time to time we refer to the disputed property items by
their assigned property unit numbers.
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Last modified: May 25, 2011