Words and Phrases - "storage tank"
15 July 2004 Internal T.I. 2004-0071101I7 F - Site de neiges usées
A corporation operating a snow removal business constructed a waste snow storage site to store waste snow and allows water to flow in culverts around the site and from there into a settling tank, with pollutants collected at its bottom, and water on the surface then discharged into the watercourse near the site. After finding that the storage tank did not fall within Class 8(c) as the Directorate did “not believe that the settling tank is a building and that it was acquired for the purpose of "manufacturing or processing" as … decantation is not a physical or chemical change produced by a technique of preparation or handling but rather a change resulting from a natural process,” the Directorate went on to find that it qualified under Class 6(e), stating:
[T[he settling tank is a water storage tank … . The fact that the water in the tank does not remain static and that there is some circulation due to the process of runoff from snowmelt and subsequent discharge of clean water into the surrounding stream does not alter the primary function of the tank which is to contain wastewater for the period of time necessary for settling.
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 - Paragraph 17(c) | waste snow storage site was qualifying surface construction | 180 |
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 - Paragraph 8(c) | tank for holding waste snow melt and decanting the pollutants was not a building used in processing | 113 |