Hospital Corporation of America and Subsidiaries - Page 84

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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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