Hospital Corporation of America and Subsidiaries - Page 88

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               We find no material differences between the facts in the               
          instant case and those facts present in Scott Paper Co. v.                  
          Commissioner, supra, and Morrison, Inc. v. Commissioner, supra,             
          relating to the primary and electrical distribution systems.  For           
          the reasons previous articulated in both of those case, we                  
          conclude that the portion of the cost of the primary and                    
          secondary electrical distribution systems in petitioners'                   
          hospitals which is equal to the percentage of the electrical load           
          carried to those systems allocable to the hospitals' equipment,             
          as stipulated by the parties, constitutes section 1245 class                
          property, depreciable over a 5-year recovery period.                        
               2.  Branch Electrical Wiring and Connections and Special               
               Electrical Equipment                                                   
               The branch electrical wiring and connections (hereinafter              
          branch wiring) relate to several items of hospital equipment and            
          are contained in many different property units including                    
          controls, battery packs, and battery chargers for the emergency             
          power generation systems (Property Unit 2200); x-ray film                   
          processing equipment (Property Unit 2244); illuminated emergency            
          entrance signs and illuminated hospital front entrance signs                
          (Property Unit 2320); medical gas control equipment and medical             
          gas alarm equipment (Property Unit 3026); hospital kitchen                  
          equipment (Property Unit 3075); equipment located in the hospital           
          laboratory and maintenance shop areas (Property Unit 3195);                 
          synchronously wired clock systems (Property Unit 3280); air                 




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