Hospital Corporation of America and Subsidiaries - Page 114

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          equipment and consequently did not relate to general building               
          plumbing.  Id.; see also Texas Instruments, Inc. v. Commissioner,           
          supra; Duaine v. Commissioner, supra.  The facts in the instant             
          case relating to the disputed property items in the subject                 
          categories are not materially distinguishable from the facts in             
          Morrison, Inc. v. Commissioner, supra, and Duaine v.                        
          Commissioner, supra.                                                        
               The disputed property items in the subject categories relate           
          to the operation of specialized kitchen or hospital equipment.              
          That equipment is related to petitioners' business of providing             
          healthcare services.  As such, the disputed property items are              
          assets accessory to petitioners' business and, consequently, they           
          do not constitute structural components of the buildings.  E.g.,            
          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.                                                        
               Accordingly, we hold that the kitchen water piping, kitchen            
          equipment steam lines, and special x-ray plumbing connections are           
          personal property, and that they are depreciable over 5-year                
          recovery periods.                                                           
               11.  Kitchen Hoods and Exhaust Systems                                 
               Kitchen exhaust hoods, exhaust fans, supply air intake fans            
          and related duct work, and dishwasher condensate return units               
          constitute Property Unit 3085.  See supra pp. 23-25.  The exhaust           



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