Court case · 1992
Publix Supermarkets, Inc. v. United States
Publix Supermarkets, Inc. v. United States, 26 Cl. Ct. 161, 69 AFTR 2d 92-1172, 92-1 USTC ¶50,240 (Cl. Ct. 1992)
U.S. Claims Court
IRS won
What the court decided
A supermarket chain's store HVAC was a structural component, not tangible personal property. It failed the "sole justification" exception in Treas. Reg. §1.48-1(e)(2) because it was not essential to the store equipment it served and because the comfort of employees and customers was one of its intended purposes. An investment-credit case that applies to MACRS through Hospital Corp. of America, 109 T.C. 21 (1997).
Why it matters for your study: The court held a supermarket's HVAC was part of the building because comfort was one of its purposes, so this case does not support short-life treatment of store HVAC.
- Category
- Asset classification
- Outcome
- IRS won
- Applies to
- All property types
- Status
- Vetted
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