Court case · 1979
Dixie Manor, Inc. v. United States
Dixie Manor, Inc. v. United States, 44 AFTR 2d 79-5442, 79-2 USTC ¶9469 (D. Ky. 1979), aff'd, 652 F.2d 57, 47 AFTR 2d 81-1298, 81-1 USTC ¶9332 (6th Cir. 1981)
U.S. District Court (D. Ky.)
IRS won
What the court decided
An investment-credit case cited in the Federal Tax Coordinator (¶ L-17246), with Fort Walton Square, Inc., 54 T.C. 653 (1970), for the rule that central heating and air conditioning installed for comfort and serving more than one room or area is a structural component of the building, not tangible personal property. It applies to MACRS through Hospital Corp. of America, 109 T.C. 21 (1997).
Why it matters for your study: The court treated central heating and air conditioning that serves several rooms as part of the building. So this case does not support 5- or 7-year treatment of comfort HVAC. Only equipment installed solely for the needs of machinery or the processing of materials or food can come out of the building.
- Category
- Asset classification
- Outcome
- IRS won
- Applies to
- All property types
- Status
- Vetted
This page explains a tax authority in plain words. It is not tax advice for your situation. Joel Salas, our Director of Tax, signs every study. Citation is provided so you or your advisor can read the primary source.