L.L. Bean, Inc., Leon Gorman, Tax Matters Person - Page 37

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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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