- 81 -
also would not relate to the operation or maintenance of the
buildings. See Piggly Wiggly S., Inc. v. Commissioner, 84 T.C.
at 748-756 (HVAC units installed to meet temperature and humidity
requirements of refrigeration equipment of grocery stores qualify
as tangible personal property). The branch electrical systems
relating to those items of equipment similarly do not relate to
the operation or maintenance of petitioners' buildings.
Accordingly, we hold that the branch electrical systems relating
to Property Units 2200, 2320, 3292, and 3075 also constitute
tangible personal property, and that they are depreciable over a
5-year recovery period.
The subject category also includes synchronously wired clock
systems (Property Unit 3280). Petitioners' expert, William J.
Neiman (Mr. Neiman), states that the clock system, located
throughout the hospital, includes clocks, timers, and personnel
time recorders that insure continuity in timekeeping. He
explains that the clock system is not found in most buildings but
49 (...continued)
such machinery is required to meet
temperature or humidity requirements which
are essential for the operation of other
machinery or the processing of materials or
foodstuffs. Machinery may meet the "sole
justification" test provided by the preceding
sentence even though it incidentally provides
for the comfort of employees, or serves, to
an insubstantial degree, areas where such
temperature or humidity requirements are not
essential.
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