The question presented, as stated by the Tax Court, is "whether certain non-load bearing gypsum drywall partitions, extending from the floor to the height of a false ceiling, erected or caused to be erected by [taxpayer] at some of its locations, are tangible personal property entitled to the investment tax credit within the meaning of [26 U.S.C. §§ 38, 46, and 48], or ... are structural components of...
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