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rupture and the molten metal will spill once the integrity of the
lining is breached and the steel shell exposed, unless the cell
unit is taken out of operation and the lining is replaced.
The parties have stipulated that (1) the cell linings have
an average useful life of approximately 3 years, and (2) the cost
of removing and replacing an exhausted lining is $23,334 plus
some miscellaneous costs. Thus, the cell lining has a life that
is independent of the cell unit as a whole, and the cost of the
lining as a percentage of the total cost of the cell unit is
substantial.8 Moreover, the evidence submitted shows that the
replacement cell lining material is a very substantial portion of
the cell unit. Cf. Badger Pipe Line Co. v. Commissioner, supra
(relocation of approximately 1,000 feet of a 25-mile 16-inch
pipeline); Libby & Blouin, Ltd. v. Commissioner, 4 B.T.A. 910,
914 (1926) (replacement of many small parts to repair a large
machine).
The parties agree on brief that the cell lining is not an
asset separate from the cell unit. However, considering the
facts and circumstances of this case, the difference between the
cell lining as a separate asset and as a substantial and
essential component is one of semantics, not substance. Cf.
8The replacement cell lining is 22.21 percent of the cost of
the rehabilitated cell unit (($17,933 + $5,401) � ($99,666 +
$5,401)).
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