- 85 -
hospital intercom, dictation, paging, and nurse call systems.
See supra pp. 17-18. During years ended 1985 through 1988, those
items were used only with those particular systems, and the
hospital blueprints indicate that the items are to be used
specifically with those systems.
Respondent agrees that the telephone enclosures are properly
classified as personal property, but contends that the conduit,
floor boxes, power boxes, and outlets that are necessary for
petitioners to use the telephones and the enclosures constitute
structural components of a building. We do not agree.
The electrical connections in the subject categories are
necessary for the operation of telephones and internal
communications equipment and are used directly with the equipment
to which they relate, and, consequently, they are considered a
part of that equipment. Scott Paper Co. v. Commissioner, supra;
Morrison, Inc. v. Commissioner, T.C. Memo. 1980-129.
Accordingly, we hold that the disputed property items in Property
Units 230 and 3090 constitute personal property and are
depreciable over 5-year periods.
6. Carpeting
The carpeting (Property Unit 2140) was installed in the
hospital facilities during construction. See supra p. 18. It
was attached to the floors of the hospitals using a general
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