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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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