Hospital Corporation of America and Subsidiaries - Page 70

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               The legislative history does not reveal a contrary                     
          intention.  The legislative history relating to section                     
          168(f)(1)(A) does not focus on the definition of section 1250               
          class property or on the definition of structural components                
          contained in section 1.48-1(e), Income Tax Regs.  See H. Rept.              
          97-201, at 67-68, 84 (1981); S. Rept. 97-144 (1981), 1981-2 C.B.            
          412, 428.  Moreover, the General Explanation of ERTA prepared by            
          the staff of the Joint Committee on Taxation states as follows:             
                    The recovery period and method the taxpayer selects               
               must be used for the building as a whole, including all                
               structural components that are real property (e.g., wiring,            
               plumbing, etc.).  Component depreciation no longer may be              
               used.  The distinction between a structural component of a             
               building, which is section 1250 property, and an item of               
               property that is section 1245 property remains the same as             
               under prior law.   * * *  [Staff of the Joint Comm. on                 
               Taxation, General Explanation of the Economic Recovery Tax             
               Act of 1981, at 85 (J. Comm. Print 1981).  Emphasis added.]            
               Additionally, see Staff of the Joint Comm. on Taxation,                
          General Explanation of the Tax Reform Act of 1986, at 90 (J.                
          Comm. Print 1987), summarizing the prohibition against the                  
          component method of depreciation under ACRS as follows:                     
          "Component cost recovery was not permitted under ACRS.  Thus, the           
          same recovery period and method had to be used for a building as            
          a whole, including all structural components."; see also H. Rept.           
          99-426, at 138 (1985), 1986-3 C.B. (Vol. 2) 138; S. Rept. 99-313,           
          99th Cong., 2d Sess. 88 (1986), 1986-3 C.B. (Vol. 3) 88.                    
               We note further that our understanding of the statutory                
          provision comports with the construction given that provision in            




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