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the nature of machinery. With regard to the earthen passenger
ramps in Weirick, we found that even if the entire ski lift were
removed, the ramps would normally remain in place and thus were
inherently permanent and did not qualify for an ITC. Therefore,
we declined to hold that the entire ski lift was property in the
nature of machinery. Weirick v. Commissioner, supra at 456.
A more revealing comparison may be drawn with the facts of
Munford, Inc. v. Commissioner, 87 T.C. 463 (1986), in which the
Commissioner allowed an ITC for certain refrigeration components,
such as pipes and pipe insulation, valves, and motors, but
disallowed an ITC for the structural elements of the refrigerated
area including the foundation, footings, walls, floor, roofing
and supports, vapor barrier, insulation, and electrical
components allocable thereto. The taxpayer in Munford argued
that although the property in issue was an inherently permanent
structure, it qualified as tangible personal property because it
was in the nature of machinery, similar to the line towers in
Weirick v. Commissioner, supra. The taxpayer asserted that the
structural elements of the refrigerated area operated together
with the refrigeration system to make the refrigerated area
function like one large refrigerator or freezer.
However, we held that the proper application of Weirick
required us to focus on the individual structural elements of the
refrigerated area rather than the facility as a whole. In
Munford, we found that the individual structural elements of the
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