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the kitchen drainage system and kitchen water piping constituted
personal property, is squarely applicable to the instant case.
Respondent contends that the disputed property items are
structural components. Respondent agrees that the disputed
property items are factually similar to property items involved
in Morrison, Inc. v. Commissioner, supra. Respondent asserts,
however, that in Morrison the taxpayers had argued that the
kitchen water piping was eligible for ITC as "other tangible
property". Respondent contends that a holding that the disputed
property items are "other tangible property" would result in
those items constituting section 1250(c) property because
petitioners are not involved in an activity enumerated in section
1245(a)(3)(B). Respondent additionally maintains that the
disputed property items are not unique to hospitals.
The terms "plumbing and plumbing fixtures" are listed
specifically in section 1.48-1(e)(2), Income Tax Regs., as
constituting structural components of a building. Nonetheless,
in Morrison, Inc. v. Commissioner, supra, we focused on the use
of the kitchen drains and concluded that the kitchen drainage
system did not relate to the operation or maintenance of a
building but rather constituted personal property because it
directly serviced the taxpayers' equipment and machinery.
Similarly, we concluded that the cafeterias' kitchen water piping
was necessary to and used directly with specific pieces of
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