Hospital Corporation of America and Subsidiaries - Page 17

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          because they are not permanent and are not an integral part of              
          the building structure but constitute personal property,                    
          depreciable over 5-year periods.  Petitioners contend that the              
          partitions are similar to the decorative lattice millwork in                
          Morrison, Inc. v. Commissioner, supra, and the movable partitions           
          in Minot Fed. Sav. & Loan Association v. United States, 435 F.2d            
          1368 (8th Cir. 1970), and King Radio Corp. v. United States, 486            
          F.2d 1091 (10th Cir. 1973), which were held to constitute section           
          1245 class property.                                                        
               Respondent contends that the partitions are structural                 
          components.  Respondent maintains that, because the disputed                
          property items are not easily reusable because of the substantial           
          support system they require, the partitions are factually                   
          distinguishable from the partitions involved in Morrison, Inc. v.           
          Commissioner, supra, Minot Fed. Sav. & Loan Association v. United           
          States, supra, and King Radio Corp., Inc. v. United States,                 
          supra.  We do not agree.                                                    
               The words "partitions" and "doors" are listed in section               
          1.48-1(e)(2), Income Tax Regs., as items that generally                     
          constitute structural components of a building.  Nonetheless, in            
          Morrison, Inc. v. Commissioner, supra, we stated that doors                 
          constitute a structural component of a building "only if they are           
          a permanent part of the * * * building, so that their removal               
          would affect the essential structure of the building."  Relying             
          on S. Rept. 95-1263, supra, 1978-3 C.B. (Vol. 1) at 415, we found           



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