Revenue ruling · 1969

Rev. Rul. 69-170

Rev. Rul. 69-170, 1969-1 C.B. 28

IRS administrative guidance

What it holds

A baseball stadium was a building (Treas. Reg. §1.48-1(e)(1)). Its fixed seats, backstop, flagpoles mounted on the stadium, and the equipment and circuitry in the scoreboard and message board were tangible personal property. The scoreboard and message board structures, the field lights (including those mounted on the stadium), the batter's eye screen, the foul-line poles, freestanding flagpoles and sign structures were inherently permanent structures, not personal property. Applies to MACRS through Treas. Reg. §1.48-1(c) and Hospital Corp. of America, 109 T.C. 21.

Why it matters for your study: Supports §1245 treatment of fixed seating and display electronics in stadiums, arenas, theaters and other venues, and classifying a display's electronics separately from its structure. Also the IRS position that exterior lighting and sign structures are not personal property.

Category
Asset classification
Applies to
All property types
Status
Vetted

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