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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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