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contend that the decorative nature of the vinyl wall coverings
and the fact that "glue-sizing" was applied to the sheetrock
walls prior to placing the wall coverings on the walls also
indicate that they were intended to be temporary. Petitioners
contend that the vinyl wall coverings are similar to the lattice
millwork in issue in Morrison, Inc. v. Commissioner, supra,
because they are "merely decorative ornamentation serving no more
than an incidental relationship to the operation or maintenance
of the building" and "could easily be removed without permanently
damaging the * * * walls". Id.
In Standard Oil Co. (Ind.) v. Commissioner, 77 T.C. 349, 405
(1981) (involving the eligibility for ITC of new service station
signs and lights), we stated that, for purposes of section
48(a)(1), "all tangible property constitutes 'tangible personal
property' unless it is excluded because it is land or an
'inherently permanent structure.'" See also sec. 1.48-1(c),
Income Tax Regs. To decide whether the service station signs and
lights constituted an inherently permanent structure, we applied
the criteria announced in Whiteco Indus., Inc. v. Commissioner,
65 T.C. at 671. Standard Oil Co. (Ind.) v. Commissioner, supra.
Additionally, in Duaine v. Commissioner, T.C. Memo. 1985-39,
for the purpose of deciding whether wall and floor tiles in a
building leased to a fast food restaurant constituted inherently
permanent structures, we applied the Whiteco criteria. In
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