Hospital Corporation of America and Subsidiaries - Page 14

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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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