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In Rev. Rul. 79-181, supra, the Commissioner determined that
structural columns which were specifically designed to support
400-ton cranes and craneway structures were tangible personal
property, because they functioned as part of the specific items
of machinery with which they were associated. The Commissioner
determined that "Any function they may have as building
components is strictly incidental to their essential function as
a part of those items of machinery or equipment." Rev. Rul. 79-
181, supra, 1979-1 C.B. at 42. Similarly, in Rev. Rul. 79-183,
supra, the Commissioner determined that a foundation which was
specially constructed to support several stamping presses was an
essential part of that machinery. Although the foundation also
served as a floor, that use was "strictly incidental to the use
that necessitated its special design." Rev. Rul. 79-183, supra,
1979-1 C.B. at 45. Likewise, in Rev. Rul. 74-391, supra, 1974-2
C.B. at 9, the Commissioner held that a raised false floor which
was designed and constructed "only to provide access" for the
installation and operation of computer equipment was essentially
part of that equipment and not a structural component of the
building. Respondent has thus allowed an ITC for certain
property which is essentially part of machinery or equipment,
notwithstanding the fact that it has an incidental function as a
structural component of a building or an inherently permanent
structure.
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