- 45 - essential for the operation of other machinery or the processing of materials or foodstuffs. Machinery may meet the "sole justification" test provided by the preceding sentence even though it incidentally provides for the comfort of employees, or serves, to an insubstantial degree, areas where such temperature or humidity requirements are not essential." [Emphasis added.] To satisfy the "sole justification" test, petitioner must establish that the heating system is machinery, the sole justification for the installation of which was to meet temperature or humidity requirements which are essential for the operation of other machinery. Sec. 1.48-1(e)(2), Income Tax Regs. Petitioner has failed to present sufficient evidence demonstrating that the sole justification of the heating system was essential for the operation of the sprinkler system. Furthermore, we have determined that the sprinkler system is not machinery but rather a structural component of the Reserve Facility. Therefore, the Reserve Facility's heating system is ineligible for an ITC. B. The Mezzanine System Petitioner also claimed an ITC for the costs of the Mezzanine System located on the ground floor of its two-story 1986 Shipping Building. The Mezzanine System occupies approximately 290 feet by 219 feet of the 1986 Shipping Building and consists of the following items: (1) Ground-level storage racks; (2) a horizontal steel structure joined to and mounted onPage: 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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