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relays served specialized functions or specific equipment used in
the taxpayer's citrus fruit processing business and therefore
qualified for ITC.
Respondent argues that the disputed property items
comprising the branch electrical systems are not identical to the
primary and secondary electrical systems involved in Scott Paper
Co. v. Commissioner, supra, and Morrison, Inc. v. Commissioner,
supra, or to the electrical connections involved in Duaine v.
Commissioner, supra, or to the "special electrical or plumbing
connections" described in Central Citrus Co. v. Commissioner,
supra, and Rev. Rul. 66-299, supra. We, however, conclude that
there are no material differences among those items and the
disputed property items in the subject category.
Respondent argues further that the wiring and conduit
located in the walls or floors of the hospitals are inherently
permanent because they are not movable. Movability, however, is
not the sole determinant as to what constitutes section 1245
personal property. Kramertown Co. v. Commissioner, 488 F.2d at
731; Consolidated Freightways v. Commissioner, 708 F.2d at 1390;
Everhart v. Commissioner, 61 T.C. at 331; Dixie Manor, Inc. v.
United States, 44 AFTR 2d at 79-5444 to 79-5446, 79-2 USTC par.
9469. The fact that some of the wiring and conduit is contained
in the walls and floors of the hospitals is not relevant in
determining whether those items are personal property. We look
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