- 110 -
services. See Morrison, Inc. v. Commissioner, supra, where we
found that restroom accessories such as vanity cabinets and
counters, even though required by local occupancy codes to be
greater in number than other business buildings, were not
accessory to the taxpayers' restaurant business but constituted
structural components of a building.
We conclude that the bathroom accessories constitute
structural components of the buildings. Although capable of
being removed and reused, there is no evidence that at the time
they were installed petitioners ever intended to remove and reuse
the bathroom accessories. We are persuaded that the bathroom
accessories are and were intended to be a permanent part of the
buildings. The bathroom accessories also serve a function that
is more than incidental to the operation of the building.
Accordingly, we hold that the bathroom accessories are
structural components of the buildings to which they relate and
therefore constitute section 1250 class property, and that they
are depreciable over the same recovery period as the buildings.
16. Acoustical Ceilings
Acoustical ceiling tiles and related grid work in
petitioners' hospitals comprise Property Unit 2260. See supra
pp. 29-30. The acoustical ceilings are movable and removable,
and their removal does not damage the building structure.
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