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Building systems classified by function and permanence under Treas. Reg. §1.48-1, Whiteco, Scott Paper, and IRS matrices—not a guaranteed 5-year list.
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Specialized Electrical Systems
Process power, emergency generation, and equipment-only electrical capacity are classified by function under Treas. Reg. §1.48-1, court tests, and IRS examiner matrices. Building life-safety power usually stays with the building. Mixed primary systems have been allocated by design load in some cases and rejected in others. This page is educational information, not tax advice.
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General Electrical Distribution
Service, house panels, and convenience circuits that light and power the building are listed structural components under Treas. Reg. §1.48-1(e)(2). A mixed primary system has been split by design load in some cases. Publication 5653 limits that functional allocation to primary and secondary electrical distribution. This page is educational information, not tax advice.
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Dedicated Equipment Wiring
Branch circuits that exist only to serve a named appliance or machine are the usual equipment-side electrical items in IRS industry matrices. General-use outlets stay with the building. Functional allocation of a mixed primary system is a separate, narrower method that Publication 5653 limits to primary and secondary electrical distribution. Educational information, not tax advice.
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Decorative and Specialty Lighting
Display, theme, and decorative lighting has been treated as personal property in some cases and IRS industry matrices, and as a structural component when it is the room’s primary illumination. Treas. Reg. §1.48-1 lists lighting fixtures among structural components. Whiteco permanence factors are a court test, not a statute. Educational information, not tax advice.
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General Building Lighting
Fixtures that illuminate corridors, stairs, restrooms, and work areas so the building can be occupied are listed structural components under Treas. Reg. §1.48-1(e)(2). Changing lamp type does not, by itself, change the class. Decorative exceptions are fact-specific and are discussed on the specialty-lighting page. Educational information, not tax advice.
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Plumbing Fixtures and Specialty Plumbing
Restroom plumbing and building domestic water and drain systems are listed structural components. Dedicated equipment hook-ups and process piping are the specialty cases in IRS matrices and in some court records. Functional allocation as described for electrical systems is not an IRS-accepted plumbing method. Educational information, not tax advice.
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HVAC and Climate-Control Systems
Central heating and air conditioning that condition a building are listed structural components. Separate machinery whose sole justification is process temperature or humidity can be personal property. Publication 5653 restaurant matrices say allocating a mixed HVAC unit is not appropriate. Educational information, not tax advice.
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Specialized Ventilation Systems
Equipment exhaust, makeup air solely for that exhaust, and process filtration are treated as following the equipment in several IRS industry matrices. Building restroom and occupancy exhaust stays with the building. The HVAC sole-justification test is a regulation exception, not an electrical load split. Educational information, not tax advice.
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Flooring and Floor Coverings
Structural slabs, ceramic tile, wood, and epoxy are treated as building in IRS examiner matrices. Strippable vinyl and carpet are treated as not permanent in several industry tables. Permanence is a Whiteco court test, not a statute, and matrices differ by industry. Educational information, not tax advice.
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Carpeting and Specialty Flooring
Carpet is treated as not permanent in the restaurant, retail, and residential IRS matrices. Permanently adhered carpet is building in the pharmaceutical table. Raised access floors and athletic surfaces are not carpet rows. Whiteco permanence factors are a court test, not a statute. Educational information, not tax advice.
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Cabinetry and Built-In Casework
The same cabinet box can be building or personal property depending on function. Residential kitchen cabinets are building in the IRS residential matrix. Dealership sales cabinets are personal property in that matrix; restroom cabinets are building. Metro National allowed cabinets on office facts. Educational information, not tax advice.
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Specialized Millwork
Theme and decorative millwork is treated as personal property in the restaurant matrix. Finish carpentry that completes an apartment often stayed with the building in AmeriSouth. Ornament is not a recovery class by itself. Whiteco permanence factors are a court test, not a statute. Educational information, not tax advice.
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Appliances and Equipment
Kitchen appliances in residential rentals are treated as class 57.0 personal property in the IRS residential matrix. Treas. Reg. §1.48-1(c) names refrigerators and production machinery as tangible personal property. Built-in stove hoods are building in that same matrix. Educational information, not tax advice.
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Restaurant Kitchen Equipment
Cooking lines, refrigeration, and dedicated hook-ups are treated as class 57.0 personal property in the IRS restaurant matrix. Smallwares may be materials and supplies under Rev. Proc. 2002-12, which is not a building-life rule. Central HVAC remains building, and allocation of a mixed unit is not appropriate. Educational information, not tax advice.
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Medical and Specialty Equipment
Imaging, laboratory, and treatment equipment is machinery under Treas. Reg. §1.48-1(c). The room, shielding, and building HVAC around it often are not. Hospital Corp. of America applied investment-credit tests under MACRS; the IRS did not acquiesce in the item results. There is no IRS medical-office matrix. Educational information, not tax advice.
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Security and Access-Control Systems
Building-protection security is a listed building system for improvement testing and is treated as building property in the retail IRS matrix. Anti-shrink surveillance is personal property in that matrix. Apartment surveillance equipment was among the items allowed in AmeriSouth. Educational information, not tax advice.
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Fire Protection and Safety Systems
Sprinkler systems, fire escapes, and related life-safety components are listed structural components in Treas. Reg. §1.48-1(e)(2). Equipment-specific suppression can be personal property in some IRS matrices. Courts have split on sprinkler-type items depending on facts. Do not declare fire sprinklers personal property as a rule. Educational information, not tax advice.
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Telecommunications and Data Wiring
Low-voltage cabling that serves equipment is treated as class 57.0 personal property in the IRS residential matrix. Building communication risers can still be structural. AmeriSouth allowed cable, phone, and data outlets on its facts. Whiteco permanence factors are a court test, not a statute. Educational information, not tax advice.
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Interior Partitions and Decorative Features
Treas. Reg. §1.48-1 lists partitions among structural components. King Radio treated a movable, non-load-bearing system as personal property. Metro National allowed some partitions and denied atrium storefront walls. Restaurant theme elements are personal property in that matrix; apartment millwork often stayed with the building in AmeriSouth. Educational information, not tax advice.
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Landscaping and Irrigation
Land is not depreciable. Landscaping that would be destroyed with a related depreciable asset is often class 00.3 land-improvement property as reproduced in Publication 946 Appendix B. The dealership matrix uses that replacement test. Trentadue classified vineyard irrigation as a land improvement and trellises as personal property. Educational information, not tax advice.
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Parking Lots, Sidewalks and Paving
Surface parking, sidewalks, curbs, and landscape islands are land improvements in IRS examiner matrices and in class 00.3 as reproduced in Publication 946. Paved parking areas are not tangible personal property under Treas. Reg. §1.48-1(c). Parking structures are buildings. Land is not depreciable. Educational information, not tax advice.
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Fencing, Gates and Site Features
Fences are not tangible personal property under Treas. Reg. §1.48-1(c). They are often class 00.3 land improvements in Publication 946. Dealership bollards are classified by what they protect. Sign structures and faces can split classes, as Whiteco and Rev. Rul. 2003-54 illustrate. Educational information, not tax advice.
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Roofing and Structural Components
Roofs, walls, floors, foundations, windows, and doors are listed structural components under Treas. Reg. §1.48-1(e)(2) and are generally section 1250 building property. Decorative roof elements can still be part of the roof. Qualified improvement property does not include roofs. Educational information, not tax advice.
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Asset Classification Evidence and Documentation
Publication 5653 lists 13 principal elements of a quality cost segregation study and nine report elements. Classification must be substantiated with records, a site inspection, and a written legal analysis. Rule-of-thumb percentages without documents are the weakest approach in that guide. Educational information, not tax advice.
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