Hospital Corporation of America and Subsidiaries - Page 16

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          overbed lights provide basic room illumination and have more than           
          an incidental relationship to the operation or maintenance of               
          petitioners' buildings.  There is no indication in the record               
          that petitioners intended the overbed lights to be temporary.  In           
          our view, removal of the light fixtures would affect the                    
          integrity of the building.                                                  
               Accordingly, we hold that the overbed lights are structural            
          components of the buildings which constitute section 1250 class             
          property, and that, consequently, they are depreciable over the             
          same recovery periods as the buildings to which they relate.                
               14.  Partitions                                                        
               The partitions (Property Unit Number 3240) in the subject              
          category are accordion-style room dividers placed in conference             
          rooms or cafeterias on tracks attached to the ceilings of                   
          petitioners' hospitals.  See supra pp. 27-28.  They are used to             
          divide areas of large rooms into smaller areas where conferences            
          and luncheons are held.  The partitions are manufactured on                 
          assembly lines and are available as catalog items from                      
          manufacturers.  None of the partitions bears any structural load.           
          The partitions are removable and at least one of them has been              
          removed from one of petitioners' hospital facilities and is                 
          currently in storage.  Removal of the partitions does not affect            
          the essential structure of the hospital buildings.                          
               Petitioners contend that the partitions do not constitute              
          structural components of the buildings to which they relate                 



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