Hospital Corporation of America and Subsidiaries - Page 15

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          component.  Nonetheless, in S. Rept. 95-1263 (see supra note 48)            
          Congress recognized that "special lighting" which has no more               
          than an incidental relationship to the operation or maintenance             
          of a building constitutes personal property.  E.g., Metro Natl.             
          Corp. v. Commissioner, supra (decorative lighting and plant grow            
          lights).  Lighting which serves as an accessory to a business               
          also constitutes personal property.  Id. (security lighting                 
          illuminating the outside perimeter of a building housing a                  
          psychiatric facility).  In Morrison v. Commissioner, T.C. Memo.             
          1986-129, we held that the taxpayers' emergency lighting                    
          constituted personal property and noted that lighting fixtures              
          and electrical connections that "do not provide basic                       
          illumination" and that are "accessory to a business" do not                 
          constitute structural components of a building.  Id.                        
               Respondent contends that the overbed lights are not similar            
          to the emergency lights involved in Morrison, Inc. v.                       
          Commissioner, but are ordinary fluorescent fixtures which provide           
          general room illumination.  We agree.                                       
               We are not persuaded that the overbed lights are "special              
          lighting" within the meaning of S. Rept. 95-1263, supra, 1978-3             
          C.B. (Vol. 1) at 415, or that they constitute an asset accessory            
          to a business within the meaning of S. Rept. 1881, supra, 1962-3            
          C.B. at 722.  The overbed lights are standard 4-tube florescent             
          light fixtures placed in the acoustical ceilings of the hospital            
          buildings.  Photographs contained in the record reveal that the             



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