- 102 -
for a property item to constitute a structural component of a
building, it must relate to "the operation or maintenance of a
building." In Scott Paper Co. v. Commissioner, 74 T.C. at 183,
we stated that "Items which occur in an unusual circumstance and
do not relate to the operation or maintenance of a building" are
not structural components of a building. Moreover, assets that
are accessory to a business constitute tangible personal
property. Metro Natl. Corp. v. Commissioner, T.C. Memo. 1987-38;
S. Rept. 1881, supra, 1962-3 C.B. at 722.
We are persuaded that the patient handrails are placed in
patient corridors to aid hospital patients who might need support
and that they are not intended to function as wall protectors.
We conclude that the handrails are assets accessory to
petitioners' business of providing healthcare services within the
meaning of S. Rept. 1881, supra, 1962-3 C.B. at 722.
Consequently, we hold that the handrails do not constitute
structural components and that the patient corridor handrails
therefore constitute personal property that must be depreciated
over 5-year recovery periods.
13. Overbed Lights and Related Electrical Connections
The overbed lights (Property Unit 4050) in the subject
category are fluorescent light fixtures placed directly over the
patient beds. See supra pp. 26-27. The lights are activated
from the bedside by a doctor, nurse, or other hospital employee
in connection with examining, bathing, or preparing a patient for
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