- 95 - 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 thatPage: Previous 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 Next
Last modified: May 25, 2011