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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.
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