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petitioners' kitchens, such as the dishwashers, coffee urns,
steam kettles, braising pans, and ice makers, they are necessary
for the operation of the kitchen equipment and are used solely
with the items of equipment to which they relate. The kitchen
equipment steam lines (Property Unit 3070), are identical to the
kitchen plumbing connections. The special plumbing connections
for the x-ray equipment (Property Unit 2244) are required for the
operation and use of the x-ray equipment and are used only with
that equipment. See supra pp. 22-23.
Petitioners contend that the kitchen water piping, the
kitchen equipment steam lines, and the x-ray equipment special
plumbing connections constitute personal property, depreciable
over 5-year periods. Petitioners maintain that those disputed
property items do not relate to the operation or maintenance of a
building because of their relationship with the kitchen or x-ray
equipment. They also contend that most commercial buildings do
not have kitchen grease waste systems, which are directly related
to petitioners' food preparation activities. In support of their
contentions, petitioners rely on Scott Paper Co. v. Commissioner,
supra; Morrison, Inc. v. Commissioner, supra; Duaine v.
Commissioner, supra; Texas Instruments, Inc. v. Commissioner,
supra; Central Citrus Co. v. Commissioner, supra; and Rev. Rul.
66-299, 1966-2 C.B. 14. Petitioners contend that our reasoning
in Morrison, Inc. v. Commissioner, supra, wherein we found that
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