RILEY, C.J.

This case of first impression involves the assessment of personal property taxes by the City of Roseville in 1982, 1983, and 1984. We granted leave to determine whether "house drops," a portion of the cable television system operating in the city, are owned by and assessable as the personal property of the cable company or, instead, are fixtures, taxable to each subscriber to whose home the cable runs.

We hold that the cable company owns the house drops for ad valorem tax purposes. Accordingly, we hold that the city properly assessed to the cable company a personal property tax on the house drops for the three years in question. We affirm the Court of Appeals decision upholding the judgment of the Michigan Tax Tribunal.

I. FACTS AND PROCEEDINGS

Petitioner-appellant, Continental Cablevision of Michigan, owns and operates a cable television system in the City of Roseville, the respondent-appellee in this matter. Essentially, the system operates through cables which transmit television signals into the residences of subscribers. Three primary components comprise petitioner's system: (1) the main cables, which run underground or aerially along utility poles, (2) the house drops, which extend from the main cables into the subscribers' homes and end in wall plates resembling telephone jacks, and (3) the converters, which affix to the outlets, linking the television sets to the cable system. At issue in the instant case is the status of the house drops for tax purposes.

Petitioner contends that a house drop, upon installation on a subscriber's real property, becomes a fixture properly assessable to the owner of the realty. Alternatively, petitioner suggests that each house drop is owned by and taxable as the personalty of each subscriber. Respondent, on the other hand, argues that petitioner retains ownership of house drops after installation. Thus, in the instant case, the house drops were properly taxed as the personal property of petitioner.

Petitioner was assessed taxes on the house drops for 1982, 1983, and 1984. After failing to obtain relief from respondent's tax board of review, the cable company filed a petition with the Michigan Tax Tribunal on May 20, 1982. Eventually, similar petitions for 1983 and 1984 were consolidated.

On February 25, 1985, a hearing was held before Tax Tribunal hearing officer Claris Kaye Cwirko. On June 7, 1985, the hearing officer rendered a proposed opinion, affirming the personal property assessments on the house drops. Petitioner filed exceptions to this proposed decision.

However, in an order entered October 29, 1985, the Tax Tribunal adopted and incorporated by reference the findings of fact and conclusions of law in the hearing officer's proposed opinion.

The Court of Appeals affirmed the decision of the Tax Tribunal. 158 Mich. App. 60; 404 N.W.2d 704 (1987).

The analysis adopted by the hearing officer, the Tax Tribunal, and the Court of Appeals is essentially identical. Each agreed that three factors must be examined in determining whether an item is a fixture: the degree of annexation to the realty, the nature of adaptation, and the intention of the parties. Each agreed that the first two elements were satisfied and that the dispositive issue in this matter was the intention of the parties. The Court of Appeals succinctly set forth its analysis as follows:

The Tax Tribunal found that the first two criteria were met by the house drops. That finding is not in dispute on appeal. Rather, the controlling issue is the third factor. The tribunal found that petitioner did not intend that the house drops become fixtures. We believe the record supports this conclusion.

When house drops are installed, the customer is charged $14.95. However, it costs petitioner approximately $40 in labor and materials to make the installation. By comparison, the charge to reconnect service to a residence with an existing house drop is $10. When service is disconnected, the house drops are not removed unless the customer so requests. Rather, service is turned off at the main cable line and the customer must turn in his converter.

Also in the financial area is petitioner's treatment of the house drops costs for accounting purposes. The labor and material costs are capitalized and depreciated over a period of time. Petitioner treats the house drops as capitalized costs for federal and state tax returns. An accounting expert opined that petitioner's accounting methodology is inconsistent with the claim that petitioner does not own the house drops.

Next, the service agreement that petitioner enters into with its customers provides for continuing control of the entire system to be exercised by petitioner. Paragraph 2 of the agreement grants petitioner the right to install, maintain, repair and replace "any and all components of the system." Paragraph 5 grants [the] exclusive right to repair and modify the system to petitioner. That paragraph also provides that the customer may not disturb, tamper with or reroute "any component of the system."

However, it should be noted that, while the agreement explicitly provides in a number of places for petitioner's right to remove the converter upon termination of service, there is no explicit provision governing removal of the house drops. As noted above, house drops are not routinely removed. However, this does not compel the conclusion that the house drops are fixtures. Rather, the economics may be such that it is advisable to leave the house drops in. The house drops do not appear to have any known salvage value. Thus, it would be uneconomical to remove them. Second, since a future resident may desire service, or the same customer may wish to reconnect in the future, and the installation cost is greater than the installation charge, it could be more economical to leave the house drops in.

In view of petitioner's accounting treatment of the house drops and that customers have no right of control over the house drops, we conclude that there is competent, material and substantial evidence to support the tribunal's conclusion that the house drops are personalty belonging to petitioner rather than fixtures or personalty belonging to the customers. [ 158 Mich. App. 64-65.]

On March 9, 1987, petitioner filed an application for leave to appeal in this Court. We granted leave on June 30, 1987. 428 Mich. 911 (1987).

II. DISCUSSION

The General Property Tax Act of Michigan mandates that all real and personal property located within the state, not expressly exempted, is subject to taxation. MCL 211.1; MSA 7.1. Real property is defined as "all lands within the state, and all buildings and fixtures thereon. . . ." Personal property, for purposes of taxation, means "[a]ll goods, chattels, and effects within the state." According to the act, if the house drops in the case at bar are fixtures, then they are taxable to the owner or occupant of the realty. On the other hand, if the house drops are personalty, then they are assessable against the owner of the house drops.

Our scope of review in this matter is narrow. In the absence of fraud, appellate review of decisions of the Tax Tribunal is limited to determining whether the tribunal made an error of law or adopted a wrong principle; the factual findings of the tribunal are final, provided they are supported by competent, material, and substantial evidence on the whole record. Const 1963, art 6, § 28; Fisher-New Center Co v State Tax Comm (On Rehearing), 381 Mich. 713; 167 N.W.2d 263 (1969).

Courts of this state have consistently applied a three-factor test to determine whether an item of property constitutes a fixture. The factors are: "`[1] annexation to the realty, either actual or constructive; [2] adaptation or application to the use or purpose to which that part of the realty to which it is connected is appropriated; and [3] intention to make the article a permanent accession to the freehold.'" Peninsular Stove Co v Young, 247 Mich. 580, 582; 226 N.W. 225 (1929); Morris v Alexander, 208 Mich. 387; 175 N.W. 264 (1919) (emphasis added).

The focus of our analysis is the intention to make the house drop a "permanent accession" to the freehold. Generally, this determination is made by examining the objective, visible facts. Michigan Nat'l Bank v City of Lansing, 96 Mich. App. 551, 554; 293 N.W.2d 626 (1980), affirmed by an equally divided Court 414 Mich. 851; 322 N.W.2d 173 (1982). See also San Diego Trust Savings Bank v San Diego Co, 16 Cal.2d 142; 105 P.2d 94 (1940). It is undisputed herein, after viewing the objective visible facts, that petitioner intended that the house drops be permanently attached to the homes they serve. See above, n 7. However, this Court has long embraced the principle that

[t]he permanency of the attachment, and its character in law, do not depend so much upon the degree of physical force with which the thing is attached, or the manner and means of its attachment, as upon the motives and intention of the party in attaching it. If the intention is that the articles attached shall not by annexation become a part of the freehold, as a general rule they will not. [ Manwaring v Jenison, 61 Mich. 117, 134-135; 27 N.W. 899 (1886). See also Woodliff v Citizens Building Realty Co, 240 Mich. 413, 416; 214 N.W. 343 (1927).]

Although the physical facts demonstrate that Continental intended that the house drops remain in the subscribers' homes permanently, we must examine the other objective evidence offered in this case in order to determine whether petitioner intended that the house drops become "accessions" to the realty. Black's Law Dictionary (5th ed), p 13, defines "accession" as "[c]oming into possession of a right or office; increase; augmentation; addition." In our view, this definition implies a transfer of ownership and control over the property attached.

In the instant case, there was no express agreement that the house drops would, upon installation, become the property of the subscribers. Thus, our essential inquiry is to determine, from the objective evidence, whether the annexing party, i.e., Continental, intended to relinquish ownership and control over the house drops. Kent Storage Co v Grand Rapids Lumber Co, 239 Mich. 161, 165; 214 N.W. 111 (1927).

The intention considered is not a secret or undisclosed intent, but the apparent intent, that inferred from all the facts and circumstances, such as the relation and situation of the annexor, the policy of the law, the manner of annexation, and the purpose or use for which the annexation was made. [36A CJS, Fixtures, § 2b, p 596. Emphasis added.]

The Court of Appeals held that the record supported the Tax Tribunal's determination that petitioner did not intend to relinquish ownership of the house drops. The Court reached this result by examining the service agreement entered into by petitioner and its subscribers, as well as the accounting and business practices of petitioner. Since "all the surrounding circumstances" are relevant for purposes of proving intent, we find that each of these inquiries was proper.

In Continental Cablevision of Michigan, Inc v City of Lansing, unpublished opinion of the Michigan Tax Tribunal, decided September 30, 1982 (Docket Nos. 53491, 64619), as in the instant case, the Tax Tribunal examined the subscription agreement to determine the intention of petitioner, but held that house drops were fixtures for tax purposes. In the instant case, after a reexamination of the agreement, the tribunal reversed itself. We find the tribunal's latter analysis to be more persuasive than the former.

We concur in the tribunal's finding that the agreement lacks any language from which it could be inferred that petitioner intended to relinquish ownership or control of the house drops. There is no language transferring title to or perfecting a gift in the subscriber. On the contrary, paragraph five provides:

All repairs and modifications of the system shall be made only by CCMC or its authorized agents. Customer agrees not to disturb, tamper with, reroute or in any way interfere with any component of the system unless authorized by CCMC. Customer further agrees that he will not attach any electric, electronic, or other type device thereto except a standard television or FM radio receiving set. Any unauthorized connection or modification of said installation will be considered a breach of the Agreement and thus cause for disconnection, and CCMC shall be entitled to recover damages for such tampering including, but not limited to, the value of CCMC service obtained without payment, the cost of repair or service, plus reasonable collection costs. [Emphasis added.]

Thus, under the provisions of this paragraph, if a subscriber tampers with the house drop, petitioner may recover from that subscriber the cost of repairing or replacing it. In our view, petitioner's reservation of this right is inconsistent with its claim that it intended the house drops to become the property of its customers upon installation.

Similarly, in paragraph two, petitioner secures the "right to install, maintain, service[,] repair and replace any and all components of the system for the purpose of this agreement on the premises to be serviced." Again, reserving this unilateral right without providing for any additional charge to the customer is further evidence that petitioner intended to maintain ownership and control over the house drops after installation. In paragraph seven, petitioner also reserves the right to disconnect service "at any time without notice and, at the option of CCMC the converter or any other equipment shall not be deemed . . . abandon[ed]. . . ." (Emphasis added.) This provision provides additional support for the tribunal's finding that petitioner intended to maintain control and ownership over the house drops. Finally, in paragraph nine, petitioner prohibits the subscriber from assigning any of its rights or duties under the agreement.

Thus, taken as a whole, the service agreement, which was drafted by petitioner, provides ample evidence of Continental's intention to retain ownership and control over the house drops. On the face of the agreement, it appears obvious to this Court that petitioner intended merely to furnish cable service to customers for a fee. The function of the property in dispute, the house drops, was simply to assist in transmitting this service.

Petitioner argues that paragraphs four and six of the service agreement militate against a finding that Continental intended to retain ownership and control over the house drops after installation. Paragraph six provides that "the customer agrees to pay all federal, state, and local taxes, if any, which may in the future be imposed . . . with respect to service and installation charges for all equipment except converters." However, at issue in the instant case is ownership of the house drops for property tax purposes. Paragraph six speaks only to paying a hypothetical tax on "service and installation charges" which may or may not be imposed in the future. Thus, we conclude that paragraph six is inapplicable in the instant action.

Paragraph four expressly reserves in petitioner ownership of the installed converter. Thus, if cable service is terminated, petitioner may enter the premises and recover the converter. Petitioner argues that because ownership of the house drops is not expressly reserved and because the house drops are not ordinarily removed when service is terminated, then petitioner intended the house drops, upon installation, to become the real property of the subscriber.

We find this argument unpersuasive. Recently, in Chillicothe Cablevision v Limbach, unpublished opinion of the Ohio Court of Appeals, decided June 5, 1987 (Docket No. 1341), the court held that the cable company retains ownership of installed house drops for property tax purposes. In reaching its result, the court discussed two prior tax commission cases, In re Telerama, unpublished opinion of the Ohio Tax Commission, decided January 8, 1975 (Docket No. 13269), holding that "set connectors" (synonym for "house drops") are fixtures because the cable company made no claim of ownership to or control over them, and Communication Properties, Inc v Lindley, CCH Ohio Tax Rpts 200-245 (Ohio Board of Tax Appeals, Docket No. 77-C-60) (August 15, 1978), holding that house drops are the personalty of the cable company since the company specifically reserved ownership of them in its service agreement.

Chillicothe, supra is analogous to the instant case because neither cable company expressly reserved ownership of the house drops. However, instead of concluding that Chillicothe Cablevision intended the house drops to become permanent accessions to the realty, the court reasoned, and we agree, that no authority requires such an explicit reservation of ownership in order for the house drops to remain the personal property of the cable company. Our task, again, is to examine all of the surrounding circumstances in order to determine petitioner's intent.

In the instant case, the Tax Tribunal and the Court of Appeals examined petitioner's business and accounting practices in order to determine its intention regarding the house drops. Similarly, in Comcast Cablevision, Inc v Sterling Heights, unpublished opinion of the Michigan Tax Tribunal, decided August 20, 1987 (Docket No. 89712), the tribunal examined the company's trade and bookkeeping customs and concluded that house drops are the taxable personal property of the cable company. Other states faced with this issue have also examined such practices in order to determine the intention of the cable company. See, e.g., Chillicothe, supra; Horizon Communications Corp v Schneider, unpublished opinion of the Missouri Tax Commission, decided January 22, 1987 (Docket No. 84-10083).

Evidence introduced at the hearing, in the case at bar, demonstrated that a subscriber pays $14.95 to have a house drop installed. However, the actual cost to petitioner for labor and materials is $40. Petitioner does not remove the house drops when service is terminated unless the customers so request. Instead, service is disconnected at the main cable. When a person moves into a residence having an existing house drop, the charge to reconnect is only $10. Petitioner claims that its failure to remove the house drops is evidence of its intent to abandon and relinquish ownership of them. We disagree and concur in the tribunal's finding that the house drops are left in place not because of ownership by the subscriber, but because it would be too expensive to remove the house drops each time service is terminated. We conclude, therefore, that petitioner has made a conscious business decision to leave the house drops intact as an incentive to future residents to subscribe. See Chillicothe, supra.

Further evidence of petitioner's intent to retain ownership of the installed house drops is the company's practice of carrying house drops on its books as depreciable capital assets and taking deductions for them on its federal and state income tax returns. At the hearing, an accounting expert testified that these practices are wholly inconsistent with the claim that petitioner does not own the house drops.

Petitioner argues that listing house drops on the company books as depreciable assets and deducting their value for income tax purposes is not controlling as to the issue of ownership. See Tele-Vue Systems, Inc v Contra Costa Co, 25 Cal.App.3d 340; 101 Cal.Rptr. 789 (1972); Bylund v Dep't of Revenue, 9 Or Tax Rptr 76 (1981).

While we agree that petitioner's tax and accounting practices are not controlling in this case, we find, nonetheless, that such practices are relevant for the purpose of proving petitioner's intention. We reiterate that "all the surrounding circumstances" must be examined in determining Continental's intention regarding the house drops.

Under the provisions of 26 U.S.C. § 167, depreciation is an allowance for deterioration of income-producing assets. The theory of depreciation assumes that property wears out with use and age and will have to be replaced. Ordinarily, only the owner of the asset suffers wear and tear and, therefore, only the owner is eligible for depreciation deductions. Urbanek v United States, 731 F.2d 870, 874, n 7 (CA Fed, 1984), cert den 469 U.S. 1034 (1984).

Petitioner cites three cases for the proposition that a person need not own property in order to claim depreciation deductions. However, in each of these cases, the person claiming the deduction had rights in the property equivalent to legal ownership.

In Helvering v F R Lazarus Co, 308 U.S. 252; 60 S Ct 209; 84 L Ed 226 (1939), the taxpayer, although not the legal titleholder, possessed a lease interest in the property for ninety-nine years. Similarly, in Gladding Dry Goods Co v Comm'r, 2 BTA 336 (1925), the taxpayer had a lease interest giving him beneficial use of the property taxed. Finally, in Loveman Son Export Corp v Comm'r of Internal Revenue, 34 T.C. 776 (1960), aff'd 296 F.2d 732 (CA 6, 1961), cert den 369 U.S. 860 (1962), a taxpayer, who had constructed a paved road, title to which was technically vested in the local municipality, was allowed to depreciate it. The commission allowed the depreciation because the road was built by the taxpayer, was necessary to the operation of the taxpayer's business, and was of no real use to anyone other than the taxpayer.

Thus, while we do not find controlling the fact that petitioner claims depreciation deductions for the house drops and lists them as assets on the company books, we do find that such practices provide additional support for the tribunal's finding that petitioner intended to retain ownership of and control over the house drops after installation.

Respondent urges this Court to treat house drops as other utility drops for purposes of taxation. MCL 211.8(g); MSA 7.8(g) provides:

For the purposes of taxation, personal property shall include:

* * *

(g) The personal property of gas and coke companies, natural gas companies, electric light companies, waterworks companies, hydraulic companies, and pipe line companies transporting oil or gas as public or common carriers, to be assessed in the township, village, or city where the personal property is located. The mains, pipes, supports, and wires of these companies, including the supports and wire or other line used for communication purposes in the operation of those facilities, and the rights of way and the easements or other interests in land by virtue of which the mains, pipes, supports, and wires are erected and maintained, shall be assessed as personal property in the township, village, or city where laid, placed, or located. [Emphasis added.]

Thus, from the language of this ninety-five-year-old statute, ordinary utility lines and supports are to be assessed as personal property of the utility company. Although cable companies are not specifically listed along with other public utilities under subsection 8(g), case law suggests that cable television may be a public utility for taxation purposes.

In White v Detroit Edison Co, a companion case to White v Ann Arbor, 406 Mich. 554; 281 N.W.2d 283 (1979), this Court held that cable television is a public utility within the meaning of the Subdivision Control Act. MCL 560.102(1); MSA 26.430(102)(1) defines a public utility:

"Public utility" means all persons, firms, corporations, copartnerships or municipal or other public authority providing gas, electricity, water, steam, telephone, sewer, or other services of a similar nature.

Since cable television was not listed in subsection 102(1), we concluded that it could only be deemed a public utility if it is an "other service of a similar nature" to one of those listed in the statute. Construing subsection 102(1) in a manner so as to carry out the intention of the Legislature, this Court reasoned that cable television is "similar" to telephone service since both transmit communication signals along power lines. Thus, for purposes of the Subdivision Control Act, cable television is a public utility.

On the other hand, in White v Ann Arbor, supra, we held that a cable system is not a public utility within the meaning of Const 1963, art 7, § 25, which provides:

No city or village shall acquire any public utility furnishing light, heat or power, or grant any public utility franchise which is not subject to revocation at the will of the city or village, unless the proposition shall first have been approved by three-fifths of the electors voting thereon. [Emphasis added.]

From the plain meaning of the words of art 7, § 25 and from a review of the Official Record of the Michigan Constitutional Convention, we concluded that "public utility" is limited to those utilities furnishing light, heat, or power. Thus, for purposes of art 7, § 25, cable television is not a public utility.

In the instant case, we do not view the language of subsection 8(g) to be as constrictive as art 7, § 25 in White v Ann Arbor; nor do we view the statute herein to be as open-ended as subsection 102(1) in White v Detroit Edison. To date, the Legislature has not included cable television as one of the utilities in subsection 8(g), and we can properly assume that the Legislature did not even contemplate cable television when it drafted subsection 8(g) in 1893.

However, although we agree that cable television is not a "public utility" as defined by the Michigan Constitution, we can find no justifiable rationale for treating house drops differently than other utility drops for purposes of taxation. We find persuasive the analogy between cable television and other public utilities drawn by Justice MOODY in his concurrence in White v Ann Arbor, supra, p 575:

Although this limited constitutional definition of public utility excludes cable television, it is imperative to recognize on a practical level that cable television possesses all the attributes of a public utility. While the term "public utility" has eluded precise definition, this Court has defined the term as follows:

"Utility means the state or quality of being useful. Was this plant [waterworks company] one useful to the public? If so, it was a public utility." Schurtz v Grand Rapids, 208 Mich. 510, 524; 175 N.W. 421 (1919).

Furthermore, in Michigan Consolidated Gas Co v Michigan Tax Comm, 4 Mich. App. 33; 143 N.W.2d 606 (1966), on remand to the Michigan State Tax Commission, In re Appeal No 1524 of Michigan Consolidated Gas Co, unpublished proposed order issued June 6, 1967, where the gas company unsuccessfully contested taxes assessed on pipe lines running from the customers' property lines to the meters attached to the homes (analogous to house drops), the commission stated:

It is anomalous to contend that the Gas Company, for rate purposes, "owns" that proportion of the service lines for which it has paid but that it has no ownership whatever for purposes of ad valorem taxation. As long as the Michigan Consolidated Gas Company is allowed to deduct the expense of maintaining the service lines and to earn a reasonable rate of return upon its contribution to the service pipelines, it is only right and proper that it suffer taxation thereon.

Accordingly, in the instant case, upon examination of petitioner's subscription agreement, its business and accounting practices, and the treatment afforded to other utilities in the area of taxation, we hold that the findings of the Tax Tribunal are supported by competent, material, and substantial evidence. We, therefore, affirm the decision of the Court of Appeals and hold that the City of Roseville properly assessed to Continental Cablevision a personal property tax for the years 1982, 1983, and 1984.

BRICKLEY, CAVANAGH, BOYLE, ARCHER, and GRIFFIN, JJ., concurred with RILEY, C.J.