Hospital Corporation of America and Subsidiaries - Page 103

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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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