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worn brick floors were unsatisfactory as the uneven floor surface
produced a hazardous condition.
In comparison to the brick floors, the Fondag cement floors
are easier to repair, become electrically nonconductive much more
quickly, and provide a more level surface, which enhances safety
and allows the use of mechanical cleaning equipment. It is clear
that replacing the bricks with Fondag cement provided a
substantial functional improvement. See Missouri Pac. RR. Co. v.
United States, 204 Ct. Cl. 837, 854, 497 F.2d 1386, 1396 (1974);
see also Southern Pac. Transp. Co. v. Commissioner, 75 T.C. 497,
718 (1980) (technical superiority of welded rail, when used to
replace jointed rail, is functionally a betterment).
The evidence shows that the old brick floors were worn out,
that patching was no longer practical, and that the introduction
of mechanical equipment required the use of a more suitable floor
material. The evidence also shows that the new floors were
replacements and substantial improvements; therefore, the
replacements were not merely repairs that kept the building in an
ordinarily efficient, operating condition. See Phillips & Easton
Supply Co. v. Commissioner, 20 T.C. 455, 460 (1953).
Finally, the new, improved floors made the property more
valuable to Vanalco in its business, because the Fondag cement
enabled Vanalco to effect faster repairs and to use mechanical
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