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hospital equipment located in the operating room, recovery room,
intensive care units, infant nurseries, radiology areas, patient
rooms, laboratories, and kitchens (Property Unit 4040) also are
property items related to furnishing medical services rather than
to providing building services. Accordingly, we hold that the
branch electrical systems relating to Property Units 2244, 3026,
3298, and 4040 constitute tangible personal property, and that
they are depreciable over a 5-year recovery period.
The parties agree that the emergency generator (Property
Unit 2200) and emergency entrance signs and illuminated hospital
front entrance signs (Property Unit 2320) are 5-year property.
In our view, those items, as well as the hospital kitchen
equipment (Property Unit 3075), constitute assets accessory to
the conduct of petitioners' healthcare business, within the
meaning of S. Rept. 1881, 87th Cong., 2d Sess. (1962), supra,
1962-3 C.B. 707, 722, and, consequently, they do not relate to
the operation or maintenance of the buildings. See Morrison,
Inc. v. Commissioner, supra (emergency lighting qualifies as
asset accessory to a business); S. Rept. 95-1263, at 117 (1978),
supra, 1978-3 C.B. (Vol. 1) 315, 41548 (special lighting,
48 In connection with the enactment of the Revenue Act of 1978,
Pub. L. 95-600, 92 Stat. 2763, the report of the Senate Finance
Committee stated among other things as follows:
the committee wishes to clarify present law by stating that
tangible personal property already eligible for the
(continued...)
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