- 43 - percentage of the system that was deemed to be used "to provide general building services". Id. at 185-186. Here, petitioner claims that 75 percent of the cost of the Reserve Facility's electrical system should be allocated to the electrical bus bar system for the transtackers. However, petitioner has not produced evidence demonstrating the percentage of electrical load attributable to the transtackers. Petitioner's unsubstantiated claim that 75 percent of the cost of the electrical system is attributable to the transtackers does not satisfy the "logical and objective" measurement required under Scott Paper Co. v. Commissioner, supra. In addition, petitioner argues that no portion of the electrical system provides "general building services" due to the unusual design of the Reserve Facility. The fact that the design of the Reserve Facility may be unusual will not, by itself, prevent its electrical system from being defined as a structural component. The electrical system provides general building services such as lighting and power and is, therefore, a structural component of the Reserve Facility. Petitioner contends that the plumbing and the sprinkler systems are not structural components, since they are built into and integrated with the rack system and are not suitable for providing general building services. Respondent maintains that the sprinkler system is listed as a structural component in the regulations and that its placement within the storage rack systemPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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