- 113 -
function that is more than incidental to the operation and
maintenance of the buildings.
Accordingly, we hold that the acoustical ceilings are
structural components of petitioners' buildings and therefore
constitute section 1250 class property and that they are
depreciable over the same recovery periods as the buildings to
which they relate.
17. Steam Boilers and Related Accessories
The steam boilers and the related accessories (Property Unit
3193) in the subject category provide heat for petitioners'
buildings and provide high-pressure steam essential to the
operation of particular items of equipment located in
petitioners' hospital facilities, such as humidifiers, air make-
up units, and central sterilization equipment. See supra p. 31.
Petitioners contend that the boilers are personal property,
depreciable over 5-year periods. Petitioners assert that
production of high-pressure steam necessary for the operation of
the hospitals' sterilizers and humidifiers is the primary reason
for the boiler's existence, and that heating the building is an
incidental function. Accordingly, petitioners contend, the
boilers satisfy the "sole justification" test of section 1.48-
1(e), Income Tax Regs.
Respondent contends that the boilers and accessories are
components of a heating system and thus constitute structural
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