- 92 -
Duaine, we held that, because the tiles were glued to the
surfaces on which they were installed and because a building's
interior tiling was included specifically as a structural
component in section 1.48-1(e)(2), Income Tax Regs., the tiles
were a permanent covering for the restaurant's walls and floors.
Id.
In contrast, we are persuaded that the vinyl wall coverings
involved in the subject category were not intended to be, and
were not, a permanent covering for the hospital walls. The walls
were prepared with glue sizing to permit easy removal of the
vinyl wall coverings without damage to the walls. The vinyl wall
coverings were attached with adhesives that also permitted easy
removal. Indeed, much of the wall coverings was removed within 8
years of installation without significant damage to the walls or
to the wall coverings.
Accordingly, we hold that the vinyl wall coverings in the
subject category constitute tangible personal property, and that
they are depreciable over a 5-year recovery period.
8. Vinyl Floor Coverings
The vinyl floor coverings and matching base cove molding
(Property Unit 2370) in the subject category are the floor
coverings originally placed in petitioners' hospital facilities
during construction. See supra pp. 20-21.
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