- 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 structuralPage: Previous 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 Next
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