- 83 -
that is not employee owned or that does not relate to the
operation or maintenance of petitioners' buildings, however, they
do constitute personal property. Petitioners, however, have not
produced evidence demonstrating which electrical outlets,
receptacles, and junction boxes are used for a qualified purpose,
and we have no basis to make that determination. Accordingly, we
sustain respondent's determination that those disputed property
items must be depreciated over the same recovery period as the
building to which they relate.
3. Wiring and Related Property Items Relating to Television
Equipment
The disputed property items in the subject category
(Property Unit 2340) consist of wiring and related property items
that relate to the television antennae and television sets
located in the hospitals. See supra pp. 16-17.
Petitioners contend that the branch wiring relating to the
television equipment is section 1245 class property, depreciable
over 5-year periods, pursuant to the reasoning of Scott Paper Co.
v. Commissioner, supra, and its progeny, as well as Rev. Rul. 66-
299, 1966-2 C.B. 14. Respondent contends that the disputed
property items in the subject category are inherently permanent
and are identified as a structural component (electric wiring) in
section 1.48-1(e)(2), Income Tax Regs. The parties agree that
the master television antennae are 5-year property.
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