- 94 -
Regs. S. Rept. 95-1263, supra, 1978-3 C.B. (Vol. 1) at 415,
however, identifies as personal property
floor coverings which are not an integral part of the floor
itself such as floor tile generally installed in a manner to
be readily removed (that is it is not cemented, mudded, or
otherwise permanently affixed to the building floor but,
instead, has adhesives applied which are designed to ease
its removal), * * *.
Applying the Whiteco criteria, we conclude that the vinyl
floor coverings are not inherently permanent. We are persuaded
that the floor coverings were not intended to be, and were not,
permanent coverings for the buildings' floors. The floor
coverings were attached with adhesives to permit easy removal
without damage to the concrete floors. Indeed, much of the floor
coverings was removed within 3 to 5 years of their installation
without damaging the underlying floors or vinyl floor coverings.
Accordingly, we hold that the vinyl floor coverings
constitute tangible personal property, and that they are
depreciable over a 5-year recovery period.
9-10. Kitchen Water Piping, Kitchen Equipment Steam Lines,
and Special X-Ray Plumbing Connections
The kitchen water piping (Property Unit 3080) in the subject
category consists of the kitchen grease waste systems (or the
grease trap system) and plumbing connections serving specific
items of kitchen equipment. See supra pp. 21-23. The plumbing
connections branch off from a hospital's main water lines and
supply water directly to specific items of equipment located in
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