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Petitioners contend that the vinyl floor coverings are not
an integral part of their buildings' floors, and, consequently,
they are not structural components but are section 1245 class
property depreciable over 5-year periods pursuant to S. Rept. 95-
1263, supra. Petitioners contend that the floor coverings are
attached to the concrete floors using general purpose latex
adhesives so that they are not permanently affixed but are easily
removed without damage to the underlying floors, that petitioners
typically remove the vinyl floor coverings every 3 to 10 years,
and that most of the vinyl floor coverings in issue have been
removed already. Petitioners further contend that the sheet
vinyl floor covering is a type of floor covering peculiar to
hospitals or other health care organizations, and that it is
section 1245 class property also because of its unusual nature.
See Scott Paper Co. v. Commissioner, 74 T.C. at 183.
Respondent contends that the vinyl floor coverings are
structural components of the buildings to which they relate
because the flooring coverings are custom cut, not readily
removable, not reusable, typical of floorings used in other
business and professional facilities, attached to the concrete
flooring by adhesives, and designed to remain in place until
their useful lives are exhausted.
The term "structural components" includes floors and any
permanent coverings for them. Sec. 1.48-1(e)(2), Income Tax
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