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T.C. 137, 184 (1980), we focus on the ultimate use of the
electrical power in petitioners' cafeterias in order to
determine whether the electrical distribution system
constitutes a structural component. An allocation should
then be made based on the qualifying and nonqualifying uses
of the power.
Similarly, in Duaine v. Commissioner, T.C. Memo. 1985-39, we
analyzed various items of property contained in a fast food
restaurant to determine whether they qualified for ITC. We
followed the reasoning of Scott Paper Co. v. Commissioner, supra,
in finding that electrical outlets and conduits that provided
localized power sources for the lessee's specialized restaurant
equipment constituted personal property.
In Rev. Rul. 66-299, 1966-2 C.B. at 16, respondent concluded
that:
special electrical or plumbing connections which are
necessary to and are used directly with a specific item of
machinery or equipment, or between specific items of
individual, machinery or equipment, are not structural
components of the building, but are essentially items of
machinery or equipment, and qualify as section 38 property
for investment credit purposes.
We analyzed that language in Central Citrus Co. v. Commissioner,
58 T.C. at 374, and stated:
Such language creates a clear distinction between property
used in the general overall operation of a building * * *
and that property which is utilized to aid in the employment
of a particular function or particular piece of property.
We find this particular dichotomy to be both reasonable and
sound and in agreement with congressional intent. * * *
[Citations omitted.]
Accordingly, we held in Central Citrus Co. that distribution
system adapters, contractors, fuses, starters, switches, and
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