- 101 -
operation or maintenance of the buildings. Petitioners further
contend that the patient corridor handrails are analogous to the
vault doors, record vault doors, night depository facilities, and
walk-up and drive-up teller's windows that, in Rev. Rul. 65-79,
1965-1 C.B. 26, constituted personal property within the meaning
of section 1.48-1(c), Income Tax Regs., because the items were
accessory to the banking business. Petitioners contend that
patient corridor handrails are clearly distinguishable from
bumper guards which are used to protect the hospital walls and
which have been treated as relating to the operation of
petitioners' buildings. Petitioners contend further that the
patient corridor handrails are reusable.
Respondent contends that the patient corridor handrails are
structural components because they relate to the operation and
maintenance of the hospital buildings. Respondent agrees that
the handrails are removable but asserts that they generally are
not reusable. Respondent does not agree that the patient
corridor handrails relate to the provision of healthcare
services. Respondent asserts that they protect walls, similar to
bumper guards, and provide support for anyone needing it, similar
to handrails in stairwells.
Section 1.48-1(c), Income Tax Regs., provides that all items
contained in or attached to a building constitute personal
property, unless they constitute structural components of a
building. Section 1.48-1(e)(2), Income Tax Regs., provides that,
Page: Previous 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 NextLast modified: May 25, 2011