L.L. Bean, Inc., Leon Gorman, Tax Matters Person - Page 43

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          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 system           




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