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Building, since it provides access to other parts of the 1986
Shipping Building and the 1979 Shipping Building, it is used for
the storage and picking of merchandise, and its underside
provides support for electrical and communication cables,
lighting fixtures, sprinkler piping, and ventilation ducts for
the first floor of the 1986 Shipping Building.
In determining whether an item is a structural component of
a building, the permanency of that component has been considered
an important factor. In Metro Natl. Corp. v. Commissioner, T.C.
Memo. 1987-38, we considered whether various items in the
taxpayer's buildings were eligible for an ITC. We found that the
structural components listed in section 1.48-1(e)(2), Income Tax
Regs., share a common characteristic--reasonable permanency.
Furthermore, we stated that "In the ordinary case, a building is
planned, designed, and constructed with the expectation that the
items listed in the regulation will remain in place indefinitely.
They are usually integrated with the building during the
construction phase and are permanent parts of the building."
An examination of the evidence in this case indicates that
the Mezzanine System is a fully integrated structural component
of the 1986 Shipping Building. The 1986 Shipping Building was
planned and designed with the integration of the Mezzanine System
in mind. On this issue, the testimony of petitioner's manager of
Facilities, Planning, and Engineering, James R. Helming, is
particularly revealing:
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