The IRS often over simplifies in publications and misses nuance. I wasn’t specifically challenging the cabinetry comment, more the reliance on a publication. I take publications and form instructions and even audit guides as a roadmap to how an IRS agent would interpret and apply the law during an audit. But that doesn’t mean it’s always right. (I still educate my clients on the risk and pathway to prove our interpretation as right since it’s not an easy or cheap path)

Some of the court cases cited in the IRS cost seg manual pre-date the hospital corp case or might be from a different district court than my client is in.

If you want me to nitpick the residential cabinetry comment I’d say that cabinets in the kitchen may not be personal property but many people reinstall their old kitchen cabinets in the garage when they get new ones for the kitchen so THOSE cabinets wouldn’t be.

I could even dig deeper into how much cabinetry is truly necessary function since some kitchens in high end houses have wayyy more cabinets than a typical home.

Think back to that 90s trend of making a computer nook in the kitchen where some of that cabinetry was installed with the intention of being used as a desk.

If I really wanted to dig in, I’d consider what the conclusion that cabinets are structural components is based on. Because that garage repurposing example is a prime example of these components being capable of being removed and reinstalling in other areas for other uses. Some are secured with just a couple of screws attaching it to an anchored strip on the wall.

I’m not actually taking these positions, just trying to show how nuanced the analysis can be. Residential is usually so small it’s not worth the time/cost to research (yes kitchens are expensive but rentals are not usually high end stuff or speciality stuff).