Thank you! This is also my understanding.
What do you t hink of this example in the Regs Sec.1.263(a)-3(k) (7) Example 18.
3 of 10 roof-top HVAC units must be replaced and can be treated as deductible repairs.
"The three roof-mounted heating and cooling units are not a significant portion of a major component of the HVAC system under (k)(6)(ii)(A) of this section, or a substantial structural part of the HVAC system, under paragraph (k)(6)(ii)(B) of this section. Accordingly, O is not required to treat the amount paid to replace the three roof-mounted heating and cooling units as a restoration of the building..."
5 out of 10 is much more than 3 out of 10 so it may not be "too gray" that these 5 units must be capitalized.
