Rev. Rul. 54-33

A company proposes to construct a `public grain warehouse' adjacent to a `public grain warehouse' already owned by it and connect the two warehouses by means of overhead and underground conveyors. The receiving, elevating, conditioning, and loading out equipment in the present warehouse will be used in connection with the new warehouse. Held , if the construction or erection of the new warehouse is completed on or before December 31, 1956, it will constitute a grain storage facility within the meaning of section 124B of the Internal Revenue Code. The conclusion would be the same, in this case, had the existing `public grain warehouse' been constructed as an emergency facility under the provisions of section 124A of the Code.