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general patient corridor area. Petitioners rely on Scott Paper
Co. v. Commissioner, 74 T.C. at 183, in support of their
contention that the disputed property items do not relate to the
operation or maintenance of a building and should not be
considered structural components because the bathroom accessories
are items which occur in an unusual circumstance.
Respondent contends that the bathroom accessories constitute
structural components of the buildings to which they relate.
Respondent asserts that the bathroom accessories are permanent,
designed to remain in place for their useful lives, and are not
economically reusable if they are removed. Respondent contends
that the number of bathrooms or type of people who utilize the
bathroom accessory does not change the nature of the disputed
property items. Respondent denies that the patient bathroom
accessories occur in unusual circumstances, pointing to hotels,
motels, and apartment buildings that also contain a large number
of bathrooms in comparison to the number of bathrooms contained
in typical office buildings.
Although we agree with petitioners that most office
buildings do not contain one bathroom for each one-to-two persons
who will be served by the business conducted within the building,
we do not agree that the large number of patient bathrooms serve
a function unique to petitioners' business or that they are
assets accessory to the business of providing healthcare
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