Norwest Corporation and Subsidiaries - Page 30

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         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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