- 36 - wiring and lighting fixtures; chimneys; stairs, escalators, and elevators, including all components thereof; sprinkler systems; fire escapes; and other components relating to the operation or maintenance of a building. * * * To the extent that any of the components relate to the overall operation and maintenance of the Reserve Facility, they are structural components of such and do not qualify as tangible personal property. Scott Paper Co. v. Commissioner, 74 T.C. 137, 182-183 (1980). 1. The Storage Rack System The Reserve Facility does not have a standard column grid typically used to support the roof and the walls in a free- standing building. Instead, the storage rack system is the structural support for the Reserve Facility. Therefore, the storage rack system not only provides shelving for the storage of petitioner's merchandise; it also provides the primary structural support for the walls and the roof of the Reserve Facility. Petitioner contends, however, that the support function of the storage rack system is secondary to that of providing racks and shelving for storage, and, therefore, the racks are not a structural component of the Reserve Facility. Petitioner relies on Rev. Rul. 79-183, 1979-1 C.B. 44; Rev. Rul. 79-181, 1979-1 C.B. 41; and Rev. Rul. 74-391, 1974-2 C.B. 9, in support of its contention.Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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