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refrigeration facility were not property in the nature of
machinery, because those elements were fixed in place and did not
serve a machinerylike function, and were not so closely related
to other property as to be considered property in the nature of
machinery. We recognized that if, when it became necessary to
replace the equipment, it would have been as economical to
replace the whole refrigeration facility, including the
structural elements, as it would have been to replace only the
equipment, we would have considered that fact an indication that
the structural components and the refrigeration equipment were so
closely related as to be considered property in the nature of
machinery. The taxpayer in Munford, however, made no such
showing. Munford, Inc. v. Commissioner, 87 T.C. at 495.
Moreover, we stated that if the purpose of the structural
elements had been simply to support and assist the functioning of
other property in the nature of machinery, we would have
considered that fact as a further indication that the structural
components and the machinery were so closely related that the
structural components should be considered property in the nature
of machinery. The structural elements in Munford however, served
a function independent of the machinery, such as keeping out
humidity, reducing temperature migration, and providing an
enclosed, protected space in which frozen foods might be stored.
Id. at 492-493.
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