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In view of the foregoing, we hold that the Mezzanine System
is a structural component of the 1986 Shipping Building and,
thus, not eligible for the ITC's in an amount exceeding that
allowed by respondent.13
Decisions will be entered
under Rule 155.
13Petitioner does not argue that the individual items of the
Mezzanine System are eligible for an ITC separately, and there is
no evidence in the record that would allow us to allocate any
cost to individual components of the Mezzanine System. We note,
however, that respondent's notice of deficiency allowed a
substantial portion of the ITC that petitioner claimed with
respect to the racks in the Mezzanine System.
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