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Chapter 7.1 |
Table of Contents | Chapter 7.3
INDUSTRY SPECIFIC GUIDANCE - CHAPTER 7.2 - RESTAURANTS
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
Large and Mid-Size
Business Division
December 27, 2004
MEMORANDUM FOR
INDUSTRY DIRECTORS
DIRECTORS, FIELD OPERATIONS
DIRECTOR, FIELD SPECIALISTS
DIRECTOR, PREFILING AND TECHNICAL GUIDANCE
DIRECTOR OF COMPLIANCE, SBSE
FROM: /s/ Henry V. Singleton
Industry Director
/s/ Steve
Burgess
Director,
Examination, SBSE
SUBJECT: Field Directive on the Planning and Examination
of Cost Segregation Issues in the Restaurant Industry
Introduction
This memorandum is intended to provide direction to effectively utilize resources
in the classification and examination of a taxpayer who is recovering costs through
depreciation of tangible property used in the operation of a restaurant business.
This LMSB Directive is not an official pronouncement of the law or the position
of the Service and cannot be used, cited or relied upon as such.
The American Jobs Creation Act of 2004, enacted October 22, 2004, modifies I.R.C.
§168. This development has been incorporated into the guidelines through the note
to Exhibit A. In addition, this directive has been modified in content and format
to conform to the Field Directive issued for the retail industry on December 16,
2004.
Background
The crux of cost segregation is determining whether an asset is I.R.C. §1245 property
(shorter cost recovery period property, 5 or 7 years) or §1250 property (longer
cost recovery period property, 39, 31.5 or 15 years). The most common example
of §1245 property is depreciable personal property, such as equipment. The
most common examples of §1250 property are buildings and building components, which
generally are not §1245 property. 1
The difference in recovery periods has placed the Internal Revenue Service and taxpayers
in adversarial positions in determining whether an asset is §1245 or §1250 property.
Frequently, this causes the excessive expenditure of examination resources.
The Director for the Retailers, Food, Pharmaceuticals and Healthcare Industry chartered
a working group to address the most efficient way to approach cost segregation issues
specific to the restaurant industry. The group produced the attached matrix
and related definitions as a tool to reduce unnecessary disputes and foster consistent
audit treatment.
Planning and Examination Guidance
Attached Exhibit A is a matrix recommending the categorization and general depreciation
system recovery period of various restaurant assets. (For recovery periods
under IRC §168(g) alternative depreciation system see Revenue Procedure 87-56, 1987-2
CB 674.) If the taxpayer’s tax return position for these assets is consistent
with the recommendations in Exhibit A, examiners should not make adjustments to
categorization and lives. If the taxpayer reports assets differently, then
adjustments should be considered. The Industry intends to update Exhibit A
regularly.
See the Cost Segregation Audit Techniques Guide for additional guidance. See
also Revenue Procedure 2002-12, I.R.B. 2002-3, 374 (Jan. 07, 2002), for the proper
treatment of smallwares.
If you have any questions, please contact Philip J. Hofmann Technical Advisor, Food
at (316) 352-7434, or Ardell Mueller, Senior Program Analyst, Retailers Food, Pharmaceuticals
and Healthcare Industry at (630) 493-5946.
Attachments: Exhibit A
LMSB DIRECTIVE ON COST SEGREGATION IN THE RESTAURANT INDUSTRY
EXHIBIT A
NOTE: In the case of certain leasehold improvements and restaurant
property, the classifications in this directive are superseded to the extent that
the American Jobs Creation Act of 2004 modifies IRC Section 168. Thus, a 15-year
straight line recovery period should replace the recovery period shown in the following
matrix if the asset is “qualified leasehold improvement property" (as defined in
IRC Section 168(e)(6)) or “qualified restaurant property” (as defined in IRC Section
168(e)(7)) placed in service by the taxpayer after October 22, 2004 and before January
1, 2008.
1 I.R.C. Section 1245 can apply to certain qualified
recovery nonresidential real estate placed in service after 1980 and before 1987.
See I.R.C. Section 1245(a)(5).
|
Asset
|
Description
|
Property Type
|
Recovery Period
|
|
Beverage Equipment
|
Equipment for storage and preparation of beverages and beverage delivery systems.
Beverage equipment includes the refrigerators, coolers, dispensing systems, and
the dedicated electrical, tubing or piping for such equipment. The dispensing
system may be gravity, pump or gas driven.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Canopies & Awnings
|
Readily removable overhang or covering, often of canvas or plastic, used to provide
shade or cover over a storefront, window, or door; or used inside a structure to
identify a particular area. Examples include applications over an exterior
door or window, or attached to interior walls or suspended from ceilings to identify
a buffet line or bar area of the restaurant. Does not include canopies that
are an integral part of a building’s structural shell, such as in the casino industry,
or over docks.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Ceilings
|
Includes all interior ceilings regardless of finish or décor, e.g. drywall or plaster
ceilings, acoustic ceilings, suspended ceilings (including all hangers, frames,
grids, and tiles or panels), decorative metal or tin finishes, kitchen plastic panels,
decorative panels, etc.
|
1250
|
Building or Building Component –
39 Years
|
|
Computers
|
Processors (CPU), direct access storage device (DASD), tape drives, desktop and
laptop computers, CRT, terminals, monitors, printers, and other peripheral equipment.
Excludes Point of Sale (POS) systems and computers that are an integral part of
other equipment (e.g., fire detection, heating, cooling, or energy management systems,
etc.).
|
1245
|
00.12 Information Systems –
5 Years
|
|
Concrete Foundations & Footings
|
Includes formwork, reinforcement, concrete block, and pre-cast or cast-in-place
work related to foundations and footings necessary for the proper setting of the
building.
|
1250
|
Building or Building Component –
39 Years
|
|
Foundations or footings for signs, light poles, canopies and other land improvements
(except buildings).
|
1250
|
00.3 Land Improvements –
15 Years
|
|
Data Handling Equipment
|
Includes adding and accounting machines, calculators, copiers and duplicating machines.
Excludes computers and computer peripheral equipment, see Computers.
|
1245
|
00.13 Data Handling Equipment, except Computers –
5 Years
|
|
Doors
|
Interior and exterior doors, regardless of decoration, including but not limited
to, double opening doors, overhead doors, revolving doors, mall entrance security
gates, roll-up or sliding wire mesh or steel grills and gates, and door hardware
(such as doorknobs, closers, kick plates, hinges, locks, automatic openers, etc.).
|
1250
|
Building or Building Component –
39 Years
|
|
Special lightweight, double action doors installed to prevent accidents in a heavily
trafficked area. For example, Eliason doors providing easy access between
the kitchen and dining areas.
|
1245
|
57.0 Distributive Trades and Services –
5 Years
|
|
Doors – Air Curtains
|
Air doors or curtains are air systems located above doors and windows that circulate
air to stabilize environments and save energy by minimizing the heated/air conditioned
air loss through open doorways and windows. They also effectively repel flying insects,
dust, and pollutants.
|
1250
|
Building or Building Component –
39 Years
|
|
Drive-Through Equipment
|
Drive-through equipment includes order taking, food delivery and payment processing
systems whether mechanical or electronic. Excludes building elements such
as doors, bays, or windows. See also Walls – Exterior, and Windows
for drive-through bays and windows.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Electrical
|
Includes all components of the building electrical system used in the operation
or maintenance of the building or necessary to provide general building services
such as electrical outlets of general applicability and accessibility, lighting,
heating, ventilation, air conditioning and electrical wiring. See also Kitchen
Equipment Hook-ups.
|
1250
|
Building or Building Component –
39 Years
|
|
Special electrical connections which are necessary to and used directly with a specific
item of machinery or equipment or connections between specific items of individual
machinery or equipment; such as dedicated electrical outlets, wiring, conduit, and
circuit breakers by which machinery and equipment is connected to the electrical
distribution system. Does not include electrical outlets of general applicability
and accessibility. See Chapter 5 of the Cost Segregation Audit Techniques
Guide for allocation examples.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Elevators & Escalators
|
Elevators and escalators, which include handrails and smoke baffles, are permanently
affixed to the building and intended to remain in place. They relate to the
operation or maintenance of the building and are structural components.
|
1250
|
Building or Building Component –
39 Years
|
|
Equipment Installation
|
Expenses incurred in the installation of furnishings and restaurant equipment.
Some examples include booths, tables, counters and interior theme décor.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Exit Signs
|
Signs posted along exit routes that indicate the direction of travel to the nearest
exit. These signs typically read "EXIT" and may have distinctive colors, illumination,
or arrows indicating the direction to the exit.
|
1250
|
Building or Building Component – 39 Years
|
|
Fire Protection & Alarm Systems
|
Includes sensing devices, computer controls, sprinkler heads, piping or plumbing,
pumps, visual and audible alarms, alarm control panels, heat and smoke detection
devices, fire escapes, fire doors, emergency exit lighting and signage, and wall
mounted fire extinguishers necessary for the protection of the building.
|
1250
|
Building or Building Component –
39 Years
|
|
Fire Protection Equipment
|
Includes special fire detection or suppression systems located in equipment hoods
or directly associated with a piece of equipment. For example, a fire extinguisher
designed and used for protection against a particular hazard created by the business
activity.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Fireplaces
|
Includes masonry and gas fireplaces, flues, chimneys and other components of
built-in fireplaces.
|
1250
|
Building or Building Component –
39 Years
|
|
Floor Coverings
|
Floor covering affixed with permanent adhesive, nailed, or screwed in place.
Examples include ceramic or quarry tile, marble, paving brick, and other coverings
cemented, mudded, or grouted to the floor; epoxy or sealers; and wood flooring.
|
1250
|
Building or Building Component –
39 Years
|
|
Floor covering that is installed by means of strippable adhesives. For the
restaurant industry, all carpeting will be treated as not permanently attached and
not intended to be permanent. Excludes rugs or tapestries that are considered
artwork and do not suffer wear and tear (e.g. Persian rugs that may appreciate are
considered artwork).
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Floors
|
Includes concrete slabs and other floor systems. Floors include special treatments
applied to or otherwise a permanent part of the floor. For example, "superflat"
finish, sloped drainage basins, raised perimeter, serving line curb, or cooler,
freezer and garbage room floors.
|
1250
|
Building or Building Component –
39 Years
|
|
Food Storage & Preparation Equipment
|
Food storage, cleaning, preparation, and delivery systems including all machinery,
equipment, furniture and fixtures used to process food items from storage through
delivery to the customer.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Heating Ventilating & Air Conditioning (HVAC)
|
Includes all components of a central heating, ventilating and air conditioning system
not specifically identified elsewhere. HVAC systems that are installed not
only to meet the temperature and humidity requirements of machinery, but are also
installed for additional significant purposes, such as customer comfort and ventilation,
are building components.
|
1250
|
Building or Building Component –
39 Years
|
|
Only separate kitchen HVAC units that meet the sole justification test are included
(i.e., machinery the sole justification for the installation of which is the fact
that such machinery is required to meet temperature or humidity requirements which
are essential for the operation of other machinery or the processing of materials
or foodstuffs.) Kitchen HVAC may meet the sole justification test even though
it incidentally provides for the comfort of employees, or serves, to an insubstantial
degree, areas where such temperature or humidity requirements are not essential.
Includes refrigeration units, condensers, compressors, accumulators, coolers, pumps,
connecting pipes, and wiring for the mechanical equipment for climate controlled
rooms such as walk-in freezers and coolers. Allocation of HVAC is not appropriate.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Kitchen Equipment Hook-ups
|
Includes separate water lines from the incoming water main to equipment (such as
steam trays, cooking vessels, or ice machines), gas lines from the building’s main
gas line to equipment (such as fryers or ovens), and special drain lines from equipment
(such as refrigerator or dishwasher) to the drain. Also includes ventilation system
or kitchen air makeup unit solely to maintain specific ventilation requirements
essential for operation of kitchen equipment, equipment exhaust hoods, and electric
outlets and conduit extending back to the circuit box to provide a localized power
source for specialized equipment. For example, a dishwasher requires electric
and plumbing hook-ups, electrical from the dishwasher to the source of electricity
(such as an outlet or junction box), and plumbing to connect the dishwasher to the
water line and the drain. Excludes outlets of general applicability and accessibility
or kitchen hand sink plumbing; see also Electrical, HVAC, and Plumbing.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
–Light Fixtures – Interior
|
Includes lighting such as recessed and lay-in lighting, night lighting, and exit
lighting, as well as decorative lighting fixtures that provide substantially all
the artificial illumination in the building or along building walkways. For
emergency and exit lighting, see Fire Protection & Alarm Systems.
|
1250
|
Building or Building Component –
39 Years
|
|
Decorative light fixtures are light fixtures, such as neon lights or track lighting,
which are decorative in nature and not necessary for the operation of the building.
In other words, if the decorative lighting were turned off, the other sources of
lighting would provide sufficient light for operation of the building. If
the decorative lighting is the primary source of lighting, then it is section
1250 property.
|
1245
|
57.0 Distributive Trades and Services -
5 Years
|
|
–Light Fixtures – Exterior
|
Exterior lighting whether decorative or not is considered section 1250 property
to the extent that the lighting relates to the maintenance or operation of the building.
Includes building mounted lighting to illuminate walkways, entrances, parking, etc.
|
1250
|
Building or Building Component –
39 Years
|
|
Pole mounted or freestanding outdoor lighting system to illuminate sidewalks, parking
or recreation areas. See also Poles & Pylons. Note* asset
class 00.3 Land improvements includes both section 1245 and 1250 property per Rev.
Proc. 87-56.
|
See Note*
|
00.3 Land Improvements –
15 Years
|
|
Plant grow lights or lighting that highlights only the landscaping or building
exterior (but not parking areas or walkways) does not relate to the maintenance
or operation of the building.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Millwork – Decorative
|
Decorative millwork is the decorative finish carpentry in the restaurant.
Examples include detailed crown moldings, lattice work placed over finished walls
or ceilings, cabinets and counters. The decorative millwork serves to enhance
the overall theme of the restaurant and is not related to the operation of the building.
Excludes cabinets and counters in a restroom; see Restroom Accessories.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Millwork - General Building or Structural
|
General millwork is all building materials made of finished wood (e.g., doors and
frames, window frames, sashes, porch work, mantels, panel work, stairways, and special
woodwork). Includes pre-built wooden items brought to the site for installation
and items constructed on site such as restroom cabinets, door jambs, moldings, trim,
etc.
|
1250
|
Building or Building Component –
39 Years
|
|
Office Furnishings
|
Includes desk, chair, credenza, file cabinet, table, or other furniture such as
workstations. Also includes telephone equipment, fax machines, and other communications
equipment. Does not include communications equipment included in other asset
classes in Rev. Proc. 87-56.
|
1245
|
00.11 Office Furniture, Fixtures, and Equipment –
7 Years
|
|
Parking Lots
|
Grade level surface parking area usually constructed of asphalt, brick, concrete,
stone or similar material. Category includes bumper blocks, curb cuts, curb
work, striping, landscape islands, perimeter fences, and sidewalks.
|
1250
|
00.3 Land Improvements –15 Years
|
|
Plumbing
|
All piping, drains, sprinkler mains, valves, sprinkler heads, water flow switches,
restroom plumbing fixtures (e.g. toilets) and piping, kitchen hand sinks, electric
water coolers, and all other components of a building plumbing system (water or
gas) not specifically identified elsewhere. Excludes water or gas connections
directly to appliances or kitchen drainage and kitchen hot water heater; see Kitchen
Equipment Hook-ups.
|
1250
|
Building or Building Component –
39 Years
|
|
Includes water, gas, or refrigerant hook-ups directly connected to appliances or
equipment, eyewash stations, kitchen drainage, and kitchen hot water heater.
For example, a dishwasher would require special water hook-up.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Point of Sale (POS) Systems
|
A register or terminal based data collection system used to control and record all
sales. Includes cash registers, computerized sales systems, and related
peripheral equipment. See also Electrical for hook-ups.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Poles & Pylons
|
Light poles for parking areas and other poles poured in concrete footings or bolt-mounted
for signage, flags, etc. Note* asset class 00.3 Land Improvements includes
both section 1245 and 1250 property per Rev. Proc. 87-56.
|
See Note*
|
00.3 Land Improvements –
15 Years
|
|
Restaurant Décor Accessories
|
Decorative mobile props such as playground equipment, potted plants, hanging mirrors,
ceiling fans, and theme related props (such as coat of arms, sporting equipment
or memorabilia, artifacts, pictures, plaques, etc., excluding non-depreciable artwork,
antiques or collectibles).
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Restaurant Furniture
|
Includes furniture unique to restaurants and distinguishable from office furniture.
For example, a high stool in a bar, dining room table and chairs, booths, lockers,
or benches. See also Office Furnishings.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Restaurant
Non-structural Theme Elements
|
Interior non-load bearing decorative structures. These are items that do not
function as part of the building and are not integrated with building elements such
as wiring, plumbing or ventilation. For example a model castle constructed
of gypsum board or plaster and wood studs would be considered a non-structural theme
element that functions merely as ornamentation. Excludes a half wall whose
function is to provide traffic control or space subdivision, see Walls - Interior
Partitions. Excludes decorative ceilings, see Ceilings.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Restroom Accessories
|
Includes paper towel dispensers, electric hand dryers, towel racks or holders, cup
dispensers, purse shelves, toilet paper holders, soap dispensers or holders, lotion
dispensers, sanitary napkin dispensers and waste receptacles, coat hooks, grab bars,
mirrors, shelves, vanity cabinets, counters, ashtrays, baby changing stations, and
other items generally found in public restrooms that are built into or mounted on
walls or partitions.
|
1250
|
Building or Building Component –
39 Years
|
|
Restroom Partitions
|
Includes shop made and standard manufacture toilet partitions, typically metal,
but may be plastic or other materials.
|
1250
|
Building or Building Component –
39 Years
|
|
Roof
|
All elements of the roof including but not limited to joists, rafters, deck, shingles,
vapor barrier, skylights, trusses, girders and gutters. Determination of whether
decorative elements of a roof (e.g. false dormers, mansard) constitute structural
building components depends on their integration with the overall roof not their
load bearing capacity. If removal of the decorative element results in the
direct exposure of building components to water, snow, wind, or moisture damage,
or if the decorative element houses lighting fixtures, wiring, or other structural
components, then the decorative elements are part of the overall roof system and
are structural components of the building.
|
1250
|
Building or Building Component –
39 Years
|
|
Security Systems
|
Includes security equipment for the protection of the building (and its contents)
from burglary or vandalism and protection of employees from assault. Examples
include window and door locks; card key access systems; keyless entry systems; security
cameras, recorders, monitors and related equipment; perimeter and interior building
motion detectors; security lighting; alarm systems; and security system wiring and
conduit.
|
1250
|
Building or Building Component –
39 Years
|
|
Signs
|
Exit signs, restroom identifiers and other signs relating to the operation or maintenance
of a building.
|
1250
|
Building or Building Component – 39 Years
|
|
Interior and Exterior Signs used for menu display or theme identity.
For pylon signs, includes only sign face. See also Poles & Pylons.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Site Preparation, Grading, & Excavation
|
In general, land preparation costs include one time cost of clearing and grubbing,
site stripping, fill or excavation, and grading to allow development of land. Clearing
and grubbing is the removal of debris, brush, trees, etc. from the site. Stripping
is the removal of the topsoil to provide a stable surface for site and building
improvements. The grading of land involves moving soil to produce a more level
surface to allow development of the land.
|
|
Land
|
|
Clearing, grading, excavating and removal costs directly associated with the construction
of buildings and building components are part of the cost of construction of the
building.
|
1250
|
Building or Building Component –
39 Years
|
|
Clearing, grading, excavating and removal costs directly associated with the construction
of sidewalks, parking areas, roadways and other depreciable land improvements are
part of the cost of construction of the improvements.
|
1250
|
00.3 Land Improvements –
15 Years
|
|
Site Utilities
|
Site utilities are the systems that are used to distribute utility services from
the property line to the restaurant building. Includes water, sanitary sewer,
gas, and electrical services.
|
1250
|
Building or Building Component –
39 Years
|
|
Site Work
|
Site work includes curbing, paving, general site improvements, fencing, landscaping,
roads, sewers, sidewalks, site drainage and all other site improvements not directly
related to the building. For sanitary sewers, see Site Utilities.
|
1250
|
00.3 Land Improvements –
15 Years
|
|
Sound Systems
|
Equipment and apparatus, including wiring, used to provide amplified music or sound.
For example, public address by way of paging a customer or background music.
Excludes applications linked to fire protection and alarm systems.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Stonework
|
Exterior decorative stonework embedded in half walls, such as patio half walls,
that are an integral part of a building’s structural shell. Such half walls
relate to the operation or maintenance of the building.
|
1250
|
Building or Building Component –
39 Years
|
|
Includes patio stonework imbedded in the ground or applied to exterior half walls
that are not an integral part of the building’s structural shell.
|
1250
|
00.3 Land Improvements –
15 Years
|
|
Trash Enclosures
|
Enclosures for waste receptacles that are attached to the building. Typically
constructed of the same materials as the building shell with either interior or
exterior access. These trash enclosures are an integral part of the building
shell and cannot be moved without damage to the underlying building.
|
1250
|
Building or Building Component –
39 Years
|
|
Freestanding enclosures for waste receptacles, typically constructed on a concrete
pad with its posts set in the concrete. Serves both safety and decorative
functions.
|
1250
|
00.3 Land Improvements –
15 Years
|
|
Upholstery
|
Any material used in the coverage and protection of furnishings.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Wall Coverings
|
Includes interior and exterior paint; ceramic or quarry tile, marble, stone, brick
and other finishes affixed with mortar, cement or grout; paneling, wainscoting and
other wood finishes affixed with nails, screws or permanent adhesives; and sanitary
kitchen wall panels such as Fiberglass Reinforced Plastic (FRP), stainless steel
or plastic wall panels.
|
1250
|
Building or Building Component –
39 Years
|
|
Strippable wallpaper that causes no damage to the underlying wall or wall surface.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Walls – Exterior
|
Includes all exterior walls and building support regardless of construction materials.
Exterior walls may include columns, posts, beams, girders, curtain walls, tilt up
panels, studs, framing, sheetrock, insulation, windows, doors, exterior façade,
brick, masonry, etc. Also includes drive-through bay, windows, and doors.
|
1250
|
Building or Building Component –
39 Years
|
|
Walls - Interior Partitions
|
Includes all load bearing interior partitions regardless of construction.
Also includes non-load bearing partitions regardless of height (typically constructed
of studs and sheetrock or other materials) that divide or create rooms or provide
traffic control. Includes rough carpentry and plaster, dry wall or gypsum
board, and other finishes.
|
1250
|
Building or Building Component –
39 Years
|
|
Interior walls where the partition can be 1) readily removed and remain in substantially
the same condition after removal as before, or 2) moved and reused, stored or sold
in its entirety.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|
Windows
|
Exterior windows, including store front windows, drive-through service and carousel
windows, and vestibule.
|
1250
|
Building or Building Component –
39 Years
|
|
Window Treatments
|
Window treatments such as drapes, curtains, louvers, blinds, post construction tinting
or interior decorative theme décor that are readily removable.
|
1245
|
57.0 Distributive Trades and Services --
5 Years
|
|