- 103 - 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 structuralPage: Previous 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 Next
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