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I think it has to do with the ?J? word. If you simply want to use the box as a pull point (no junctions or terminations), then I guess it wouldn?t matter much. But the primary function of a junction box is to provide a location for joining wires. If the junction point ever gets loose, and if the box is covered by the wall, how would you find the box, let alone get into it to make the repair?
 
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A fitting or box, with an access cover, must be accessable, without removing any building finish.
 
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Kal:

Years ago I was called to a 26 story high-rise for loss of power to a penthouse MCC with the elevator feed from the MCC.

Isolated the loads and meggered the feeders, had a dead short on one phase. This was a parallel feeder 5 sets 500 kcmil. So I isolated the feeder located the damaged feeder and restored power.

In a 26 story building there should have been strain relief per the NEC. I could not find any JB's. After several days of trying various trouble shooting ideas, I decided to locate the electrical contractor that wired the building. The foreman told me exactly where the JB's where.

We opened the walls and were close to the location of the JB's only one problem; they faced the JB'S cover away from the hall into the apartments. Lucky for us the boxes where in the bathrooms facing the bathtub behind tile walls. Of cause the short was located in the last bathroom we destroyed, tile walls ect. The contractor had used strain relief. Pieces of 2X4 cut into wedges and hammered into the conduits with the added benefit of no bushings.

Had the JB's been installed per the NEC we still would have had problem but nothing like the cost incurred by the apartment complex, with the hidden JB's. They did not go after the contractor for some reason.
 
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In my previous post I called the boxes JB's junction boxes I should have stated these were pull boxes, NO SPLICES.
 
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