Hospital Corporation of America and Subsidiaries - Page 92

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          with which they are used, and are not readily removable.                    
          Additionally, with regard to the electrical outlets, receptacles,           
          and junction boxes located in laboratory and shop areas,                    
          respondent asserts that those disputed property items may be used           
          to power nonhospital equipment or equipment relating to the                 
          operation or maintenance of the buildings.  To decide whether the           
          disputed property items in the subject category constitute                  
          personal property or structural components of the buildings to              
          which they relate, we apply the reasoning in Scott Paper Co. v.             
          Commissioner, supra, and cases following its rationale.                     
               In Scott Paper Co. v. Commissioner, 74 T.C. at 182-183, we             
          noted that even though section 1.48-1(e)(2), Income Tax Regs.,              
          lists items such as "wiring and lighting fixtures" in describing            
          structural components, to constitute a structural component of a            
          building, the item nonetheless must relate to the operation or              
          maintenance of the building.  Subsequently, in Morrison, Inc. v.            
          Commissioner, T.C. Memo. 1986-129, we found that much of the                
          electrical distribution systems constituted personal property.              
          We stated:                                                                  
               Respondent points out that the reasonable adaptability of              
               the electrical distribution system with minimal effort to              
               accommodate another cafeteria, a restaurant or a retail                
               sales establishment such as a furniture store, indicates               
               that the system relates to the overall operation or                    
               maintenance of the building rather than relating to the                
               function of specific pieces of kitchen machinery or                    
               equipment.  Respondent recognizes that his argument is                 
               contrary to our holding in Scott Paper Co., supra.                     
               Following our holding in Scott Paper Co. v. Commissioner, 74           




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