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1. Primary and Secondary Electrical Distribution Systems
The primary electrical distribution systems,6 which the
parties have designated as Property Unit 1900, accept electricity
from outside electrical power sources and deliver it to the
secondary electrical distribution systems contained within the
hospital facilities. Generally, the items comprising the primary
electrical distribution systems consist of (1) the electrical
wire and conduit extending from the outside power sources to the
main electrical distribution panels and (2) the main electrical
distribution panels themselves, also known as main switchgears.
In some instances, motor control centers or transformers also may
be included.
The secondary electrical distribution systems receive
electricity from the primary electrical distribution systems and
deliver it to the various electrical end-users located throughout
petitioners' hospital facilities (e.g., lighting fixtures, fire
protection systems, and hospital equipment). The items
comprising those secondary electrical distribution systems
consist of the electrical wire and conduit extending from the
primary electrical distribution panels to the secondary
electrical distribution panels, the secondary electrical
6 Respondent agrees that the items comprising petitioners'
primary and secondary electrical distribution systems are similar
to those items in issue in Morrison, Inc. v. Commissioner, T.C.
Memo. 1986-129, affd. 891 F.2d 857 (11th Cir. 1990).
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Last modified: May 25, 2011