Hospital Corporation of America and Subsidiaries - Page 112

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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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