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Our inquiry in the instant case is thus not to consider
whether the Reserve Facility as a whole constitutes property in
the nature of machinery. Rather, the question presented is
whether the individual structural elements of the Reserve
Facility qualify as property in the nature of machinery which is
eligible for an ITC. The structural elements of the Reserve
Facility are fixed in place and are similar to the structural
elements involved in Munford. The transtackers, like the
refrigeration equipment in Munford, are the only components of
the Reserve Facility that could be considered to have a
machinerylike function. Petitioner has not shown that if it
became necessary to replace the transtackers in the Reserve
Facility, it would be as economical to replace the entire
facility, including the structural elements, as it would be to
replace only the transtackers. Additionally, petitioner admits
that the walls and the roof of the Reserve Facility have a
function separate and apart from merely supporting the
transtackers. Petitioner concedes that the purpose of the
roofing and wall panels connected to the racks is merely to
protect petitioner's inventory. Although the guide tubes and the
electrical bus bars for the transtackers are attached to the
racks, the primary purpose of the racks is not to support this
equipment but, instead, to hold petitioner's merchandise and to
support the roof and the walls that protect the merchandise.
While the floor slab provides a smooth surface for the
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