- 116 - equipment are essential functions of the boilers, and that neither function is incidental to the other. Accordingly, the "sole justification" test is not satisfied. See sec. 1.48- 1(e)(2), Income Tax Regs. Based on the foregoing, we conclude that the boilers are analogous to the electrical distribution system involved in Scott Paper Co. v. Commissioner, 74 T.C. 137 (1980). The record, however, does not demonstrate the percentage of the steam produced by the boilers that is used to operate hospital equipment. Consequently, we have no "logical and objective measure" of the portion of the boilers that would constitute section 1245 personal property. See Scott Paper Co. v. Commissioner, supra at 165. Accordingly, we sustain respondent's determination that the boilers must be depreciated over the same period as the buildings to which they relate. To reflect the foregoing, Appropriate orders will be issued.Page: Previous 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116
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