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surgery. General reading lights, vanity lights, night lights,
and large double-pane windows provide other illumination for the
patient rooms.
Petitioners contend that the overbed lights are not
structural components of their buildings, but that they are
section 1245 class property, depreciable over 5-year recovery
periods. Petitioners assert that the overbed lights are not
intended or designed to be used for basic patient room
illumination, they are used solely by doctors, nurses, and staff
in examining patients and providing health care services, and
that they are accessory to petitioners' businesses. Petitioners
further contend that the overbed lights fit the description of
special lighting delineated in S. Rept. 95-1263, supra, 1978-3
C.B. (Vol. 1) at 415, and, therefore, the overbed lights
constitute section 1245 class property.
Respondent contends that the overbed lights are structural
components of the buildings to which they relate. Respondent
also contends that the overbed lights are permanently installed
in the ceiling of the buildings, provide general room
illumination, and are identical to other fluorescent lights in
the hospital buildings. Additionally, respondent disputes
petitioners' assertion that the overbed lights are used
exclusively by healthcare professionals.
Section 1.48-1(e)(2), Income Tax Regs., includes "electric
wiring and lighting fixtures" as an example of a structural
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