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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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