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to the ultimate use of the electrical power conveyed by the
branch electrical systems to decide whether the disputed property
items constitute structural components or personal property.
Scott Paper Co. v. Commissioner, supra; Morrison, Inc. v.
Commissioner, supra.
From the foregoing, we learn that a disputed property item
constitutes a structural component to the extent that it
furnishes electrical power for a function or equipment that
relates to the operation or maintenance of a building.
Conversely, to the extent that a disputed property item furnishes
electrical power for a function or equipment that does not relate
to the operation or maintenance of a building, the disputed
property item constitutes tangible personal property. Scott
Paper Co. v. Commissioner, supra; Central Citrus Co. v.
Commissioner, supra; see also Texas Instruments, Inc. v.
Commissioner, supra; Morrison, Inc. v. Commissioner, supra;
Duaine v. Commissioner, supra.
The x-ray film processing equipment (Property Unit 2244),
medical gas control equipment and medical gas alarm equipment
(Property Unit 3026), and hospital central sterilization
equipment (Property Unit 3298) aid in the rendition of healthcare
services and, therefore, the branch electrical systems relating
to that equipment do not relate to the operation or maintenance
of the buildings. Branch electrical systems relating to items of
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