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respondent agrees is 5-year personal property. We refer to the
branch wiring and special electrical equipment in issue in the
subject category collectively as the branch electrical systems.
Petitioners contend that the branch electrical systems are
section 1245 class property pursuant to the reasoning of Scott
Paper Co. v. Commissioner, 74 T.C. 137 (1980), and its progeny,
as well as Rev. Rul. 66-299, 1966-2 C.B. 14.47 Petitioners
contend that the parties agree that virtually every item to which
the branch wiring relates was appropriately classified as section
1245 class property.
Respondent, however, contends that the disputed property
items in the subject category are inherently permanent and are
identified as a structural component (electric wiring) in section
1.48-1(e)(2), Income Tax Regs. On brief, respondent segregates
the disputed property items into individual segments of conduit,
electrical wiring, junction boxes, outlets, and receptacles.
47 A revenue ruling reflects respondent's position on an issue
and is not binding precedent upon the Court. See Halliburton Co.
v. Commissioner, 100 T.C. 216, 232 (1993), affd. without
published opinion 25 F.3d 1043 (5th Cir. 1994); Stark v
Commissioner, 86 T.C. 243, 250-251 (1986); Neuhoff v.
Commissioner, 75 T.C. 36, 46 (1980), affd. 669 F.2d 291 (5th Cir.
1982). We disregard a revenue ruling, if it conflicts with the
statute it supposedly interprets, with the statute's legislative
history, or if it is otherwise unreasonable. E.g., Threlkeld v.
Commissioner, 848 F.2d 81, 84 (6th Cir. 1988), affg. 87 T.C. 1294
(1986). However, we may adopt its reasoning if we agree that the
ruling correctly applies the law. Estate of Lang v.
Commissioner, 64 T.C. 404, 406-407 (1975), affd. in part and
revd. in part 613 F.2d 770, 776 (9th Cir. 1980); Keating v.
Commissioner, T.C. Memo. 1995-101.
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