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purpose latex adhesive. Most of the carpeting already has been
removed.
Petitioners contend that the carpeting was not a structural
component of petitioners' hospital buildings within the meaning
of section 1.48-1(e)(2), Income Tax Regs. Petitioners contend
that the carpeting was easily removed, its removal did not damage
the concrete floors of the hospitals, and that, if necessary, the
carpeting could have been reinstalled in other locations with new
adhesives. Additionally, petitioners contend that the carpeting
was not an integral part of, or a permanent covering for, the
hospital floors. Petitioners further contend that section 1.48-
1(e)(2), Income Tax Regs., does not list carpeting as a
structural component of a building. Accordingly, petitioners
contend, the carpeting must be an integral part of, and a
permanent covering for, the concrete floors of petitioners'
hospitals to constitute a structural component of a building
under section 1.48-1(e)(2), Income Tax Regs.
Respondent contends that the carpeting constitutes a
structural component. Respondent maintains that the carpet is
typical of carpeting used in other business and professional
facilities, is custom cut, is attached to the concrete flooring
by adhesives, is designed to remain in place until its useful
life is exhausted, provides a minimally acceptable floor finish,
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