Hospital Corporation of America and Subsidiaries - Page 101

                                       - 84 -                                         

               We conclude for the reasons discussed supra relating to the            
          branch electrical systems that the branch wiring in the subject             
          category constitutes assets accessory to the conduct of                     
          petitioners' healthcare business within the meaning of S. Rept.             
          1881 supra, 1962-3 C.B. at 722.  The disputed property items in             
          the subject category do not relate to the operation or                      
          maintenance of the buildings.  Consequently, we hold that the               
          wiring and related property in Property Unit 2340 constitute                
          tangible personal property, depreciable over a 5-year recovery              
          period.                                                                     
               4-5.  Conduit, Floor Boxes, Power Boxes and Outlet Jacks               
                    Relating to Telephone Equipment and Electrical Wiring,           
               Conduit, and Connections Relating to Internal                          
                     Communications Equipment                                         
               The telephone equipment in the subject categories (Property            
          Unit 2330) includes conduit installed specifically to house the             
          telephone wiring, telephone floor boxes, telephone power boxes,             
          and telephone outlet jacks, which cannot be used for any purpose            
          other than as a connection point for petitioners' telephones.               
          See supra p. 17.  Respondent agrees that those items are required           
          for the use and operation of the telephones in petitioners'                 
          hospitals and, during the years in issue, were used only with the           
          telephones and telephone equipment located in the hospitals.                
               The internal communications equipment in dispute (Property             
          Unit 3090) consists of wiring and conduit, junction boxes,                  
          outlets, and sleeves that are necessary for the operation of the            




Page:  Previous  74  75  76  77  78  79  80  81  82  83  84  85  86  87  88  89  90  91  92  93  Next

Last modified: May 25, 2011