Hospital Corporation of America and Subsidiaries - Page 91

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          Respondent contends that the conduit is designed to remain in               
          place throughout its expected useful life, is identical to other            
          conduit which petitioners have agreed is a structural component,            
          and is typical of electrical conduit used at other commercial               
          establishments.  Respondent contends that the electrical wiring             
          is not designed or installed with a particular piece of                     
          equipment, is not easily removable, and is not economically                 
          practicable to reuse.  Respondent contends that none of the                 
          electrical outlets, receptacles, and junction boxes are                     
          inextricably linked to specific items of machinery, they are not            
          moved, they are typical of outlets, receptacles, and junction               
          boxes used in commercial facilities, and they relate to the                 
          operation of the buildings in that they provide points for the              
          provision of power for many property items including employee               
          radios in the laboratories and power tools in the shop areas.               
               As we understand respondent's position, respondent agrees              
          that the disputed property items in the subject category are                
          necessary for, and used exclusively with, the operation of                  
          various items of equipment.  Nevertheless, respondent contends              
          that the branch electrical systems are structural components                
          because they were not designed for or installed with the specific           
          equipment to which they relate, they are adaptable for other                
          purposes, are composed of standard electrical supplies, have                
          useful lives not inextricably linked to the specific equipment              





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