- 104 - 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 thePage: Previous 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 Next
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