-30-
increased the value of the building so as to require them to be
capitalized. We find, however, that had there been no remodeling,
the asbestos would have remained in place and would not have been
removed until a later date. In other words, but for the remodeling,
the asbestos removal would not have occurred.13
The asbestos removal and remodeling were part of one
intertwined project, entailing a full-blown general plan of
rehabilitation, linked by logistical and economic concerns. "A
remodeling project, taken as a whole, is but the result of various
steps and stages." Bank of Houston v. Commissioner, T.C. Memo.
1960-110.14 In fact, removal of the asbestos fireproofing in the
Douglas Street building was "part of the preparations for the
remodeling project." See id. Before remodeling could begin, nearly
every ceiling light fixture in the building was ripped down and
crews removed all the asbestos-containing materials that had been
sprayed on the columns, I-beams, and decking between floors, as well
as the floor tiles in the customer lobbies. Only then could the
remodeling contractor perform its work. As described above, the
13 While no remodeling was done in the parking garage, the
record indicates that it was financially advantageous to remove
the asbestos-containing materials in the parking garage at the
same time as the abatement activity throughout the building.
14 Petitioner attempts to distinguish Bank of Houston v.
Commissioner, T.C. Memo. 1960-110, from the present case by
arguing that only one contractor was used in Bank of Houston
while it used two. We do not find that distinction to be of any
significance. Two different contractors were necessary in this
case because removing the asbestos-containing materials required
special skills that the remodeling contractor did not possess.
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