|
|
|
|
|
|
|
|
|
|
|
|
|
HOSPITAL
CORP OF AMERICA & SUBSIDIARIES vs. COMMISSIONER |
|
|
|
|
|
|
|
|
|
|
JULY 24, 1997 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Summary of Findings
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
COURT'S |
|
|
|
|
|
|
|
|
|
|
ITEM # |
DESCRIPTION |
CONCLUSION |
|
|
COMMENTS |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1 |
Primary & Secondary Electrical
System |
Allocate based on Load |
|
|
Scott Paper Co. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
2 |
Branch Electrical Wiring, Connections
& Special Elect. Equip. for: |
|
|
|
|
|
|
|
|
|
|
|
|
Battery Packs |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
Battery Chargers |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
X-ray film processing Equipment |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
Illuminated entrance Signs |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
Medical Gas Control &
Gas Alarm |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
Hospital Kitchen Equip. |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
Misc. Elect. Outlets etc.
located in Labs & Maintenance Areas |
5 Year if not related to the
operation of building. |
Depends on specific use. |
|
|
|
|
|
|
Synchronously wired Clocks |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
Computer Rm. Air Conditioners |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
Sterilization Equip. |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
Hospital Equip. located in
Various Areas |
5 Year |
|
|
Not for the operation of a building. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
3 |
Wiring Related to Television
Equip. |
5 Year |
|
|
Accessory to Business within
meaning of S. Rep. 1881 supra, 1962-3 C.B. at 722 |
|
|
|
|
|
|
|
|
|
|
|
|
|
45 |
Conduit, Floor Boxes, Power
Boxes & Outlet Boxes
Related to Telephone Equip. |
5 Year |
|
|
Used directly with equipment. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
6 |
Carpeting - Applied with Adhesive |
5 Year |
|
|
Rev. Rul 67-349 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
7 |
Vinyl Wall Covering |
5 Year |
|
|
Not Structural Component - Removable |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
8 |
Vinyl Floor Covering |
5 Year |
|
|
Not Structural Component - Removable |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
910 |
Kitchen Water Piping, Steam
Lines & x-ray Plumbing |
5 Year |
|
|
Accessory to Business within
meaning of S. Rept. 1881 supra, 1962-3 C.B. at 722 |
|
|
|
|
|
|
|
|
|
|
|
|
|
11 |
Kitchen Hoods & Exhaust Systems |
5 Year |
|
|
Sole Justification Test. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
12 |
Patient Hand Rails |
5 Year |
|
|
Accessory to Business within
meaning of S. Rept. 1881 supra, 1962-3 C.B. at 722 |
|
|
|
|
|
|
|
|
|
|
|
|
|
13 |
Overhead Lights & Related
Electrical Connections
(in ceiling fluorescent) |
Depreciate over life of Building |
|
Not Special Lighting. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
14 |
Partitions (Accordion-Style
Room Dividers) |
5 Year |
|
|
Incidental to operation of a
building. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
15 |
Patient Bathroom Accessories
& Mirrors |
Depreciate over life of Building |
|
Structural Components. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
16 |
Acoustical Ceilings |
Depreciate over life of Building |
|
Sole Justification test not met. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
17 |
Steam Boilers & Related
Accessories |
Depreciate over life of Building |
|
Sole Justification test not met.
No "logical or objective " allocation demonstrated.
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|