Hospital Corporation of America and Subsidiaries - Page 25

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          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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