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to the operation and maintenance of petitioners' buildings. See
supra p. 12.
Petitioners contend that the portion of the primary and
secondary electrical distribution systems which carry electrical
loads to particular items of business equipment constitutes
section 1245 class property within the meaning of sections 1.48-
1(c) and 1.1245-3(b), Income Tax Regs., because that portion of
the electrical distribution systems does not relate to the
operation or maintenance of a building. Respondent counters that
those disputed property items are structural components of the
buildings to which they relate because they are inherently
permanent and are not readily removable.
Respondent agrees that our decision in Morrison, Inc. v.
Commissioner, supra, as affirmed by the Court of Appeals for the
Eleventh Circuit, provides authority for petitioners' position
that the primary and secondary electrical distribution systems
are not structural components to the extent of the load
percentages that the parties stipulated are carried to equipment.
Our holding in Morrison follows our holding in Scott Paper Co. v.
Commissioner, 74 T.C. 137, 186-187 (1980), that the portion of
the taxpayer's primary electrical distribution system which did
not relate to the overall operation or maintenance of buildings
constituted tangible personal property under section 48(a)(1)(A)
and therefore was eligible for ITC. Respondent, however, urges
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