General Building Lighting

Corridor, stair, restroom, parking-garage, and open-office lighting make a building usable. Treas. Reg. §1.48-1(e)(2) captures that function by listing lighting fixtures among structural components, together with electric wiring, plumbing, central heating and air conditioning, partitions, floors, ceilings, sprinkler systems, and fire escapes. Tangible personal property under section 1.48-1(c) excludes those structural components. A building under section 1.48-1(e)(1) is a structure enclosing space, usually roofed, used for shelter, housing, or working, office, parking, display, or sales space — including garages.

Hospital Corp. of America held that these investment-credit definitions still apply under MACRS. The IRS acquiesced in that legal conclusion, not in each item the court placed in section 1245. General building lighting is therefore usually recovered with the building: 27.5 years if the building is residential rental property, or 39 years if it is nonresidential real property. LED retrofits, fluorescent-to-LED lamp changes, and occupancy sensors do not, by themselves, move the fixtures into a five-year class.

Metro National treated lay-in lighting in false ceilings as a structural component and allowed decorative and security lighting as personal property on the same facts. Shoney’s South allowed decorative chandeliers where separate recessed fixtures provided primary light; the IRS nonacquiesced. Those opinions show courts splitting lighting by function, not a rule that interior lighting is personal property. Whiteco’s six permanence factors are a court test for inherently permanent structures. A lay-in troffer in a grid ceiling may be removable, but Metro National still treated that lighting package as part of the building on those facts. Removability is one Whiteco question, not a statute that overrides the lighting-fixture list.

Publication 5653 matrices keep general interior lighting with the building. The residential matrix treats ceiling fans that are typically the primary light source as residential rental property. Guest-room lighting that occupies the room is building in the casino and hotel matrix. Building-mounted exterior lighting is building; pole-mounted site lighting is commonly grouped with land improvements in class 00.3 as reproduced in Publication 946 Appendix B, subject to activity-class overrides under Rev. Rul. 2003-81. Emergency exit lighting is listed with fire-protection systems in Treas. Reg. §1.263(a)-3.

AmeriSouth kept most apartment finish claims with the buildings. Boddie-Noell rejected after-the-fact lighting percentages that were not supported by contemporaneous records. A quality file photographs the occupied lighting, cites the regulation, and leaves decorative exceptions to a separate, documented set of fixtures.