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requirements essential for the operation of petitioners' kitchen
equipment and they provide only incidental benefit to
petitioners' employees. The dishwasher condensate return units
and related piping were installed solely to provide emergency hot
water for petitioners' dishwasher equipment. The disputed
property items in the subject category consequently do not
constitute structural components of petitioners' buildings.
Morrison, Inc. v. Commissioner, supra; Duaine v. Commissioner,
supra; sec. 1.48-1(e)(2), Income Tax Regs.
Accordingly, we hold that the disputed property items in the
subject category constitute personal property, and that they are
depreciable over 5-year recovery periods.
12. Patient Corridor Handrails
Patient corridor handrails (Property Unit 3190) are
handrails placed along the patient corridors of petitioners'
hospital facilities to assist patients. See supra pp. 25-26.
The handrails can be removed from the walls by removing the bolts
holding them in place, and their removal would not damage the
hospital walls. In some instances, the handrails have been
removed.
Petitioners contend that the patient corridor handrails
constitute section 1245 class property, depreciable over 5-year
periods. Additionally, petitioners contend that the disputed
property items in the subject category are peculiar to hospitals
and other medical facilities and that they do not relate to the
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