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that constitute section 1250 class property and property items
that constitute section 1245 class property. The legislative
history of MACRS does not reveal a contrary intention.
In support of the position that an analysis based on ITC is
inappropriate for cost recovery purposes, respondent relies on
language contained in Grinalds v. Commissioner, T.C. Memo. 1993-
66, that "the 'sole justification' test relates to the investment
tax credit, which has provisions and policies of its own, and it
provides only limited guidance, if any, in interpreting section
168(i)(6), the statute directly involved here." The "sole
justification" test refers to the provision in section 1.48-2(e),
Income Tax Regs., which specifically excludes from the definition
of a structural component "machinery the sole justification for
the installation of which is the fact that such machinery is
required to meet temperature or humidity requirements which are
essential for the operation of other machinery." Sec. 1.48-2(e),
Income Tax Regs. In Grinalds, we did not focus on the definition
of section 1245 class property and section 1250 class property.
Therefore that case is distinguishable and inapplicable to the
issue of whether tangible property constitutes section 1245 class
property or section 1250 class property for purposes of ACRS and
MACRS.
Based on the foregoing, we conclude that the tests developed
to ascertain whether property constituted tangible personal
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