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Petitioners maintain that the acoustical ceilings involved in the
subject category are analogous to the vault doors, walk-up and
drive-up teller's windows, and teller's booth installed by a bank
which respondent held constituted tangible personal property
within the meaning of section 1.48-1(c), Income Tax Regs.,
because their removal would not affect the continued operation of
the bank building as a building, even though their removal would
necessitate making repairs to the building and could affect the
continued operation of the bank's business. Rev. Rul. 65-79,
1965-1 C.B. 26.
We conclude that the acoustical ceilings are not materially
distinguishable from the false ceilings described in Metro Natl.
Corp. v. Commissioner, supra, or the suspended ceilings depicted
in Texas Instruments, Inc. v. Commissioner, supra. Movability is
only one characteristic to be considered in determining whether
property is a structural component. Everhart v. Commissioner, 61
T.C. 328, 331 (1973). We are persuaded that the acoustical
ceilings were designed and intended to be a permanent part of the
buildings and that their removal would affect the operation of
the buildings in which they were installed. We do not think that
the incidental benefit of trapping some dust and dirt and
providing sound reduction is sufficient to convert the ceilings
into assets accessory to petitioners' healthcare business as
petitioners contend they are. The acoustical ceilings serve a
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