Are HVAC units qualified leasehold improvement property (qlip)?

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The IRS recently concluded in CCA 201310028 that HVAC units located on either the roof of a building or a concrete pad adjacent to the building were not qualified leasehold improvement property (QLIP) for depreciation purposes. As a result, the HVAC units were subject to depreciation over a 39-year recovery period instead of 15 years.

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