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moved, and has it in fact been moved? (2) Is the property
designed or constructed to remain permanently in place? (3) Are
there circumstances which tend to show the expected or intended
length of affixation, i.e., are there circumstances which show
that the property may or will have to be moved? (4) How
substantial a job is removal of the property and how time-
consuming is it? Is it "readily removable"? (5) How much damage
will the property sustain upon its removal? and (6) What is the
manner of affixation of the property to the land?
Movability itself is not the controlling factor in deciding
whether the property lacks permanence. Kramertown Co. v.
Commissioner, 488 F.2d 728, 731 (5th Cir. 1974), affg. T.C. Memo.
1972-239; see also Consolidated Freightways v. Commissioner, 708
F.2d 1385, 1390 (9th Cir. 1983) (a variety of factors are
considered, including, where possible, the function and design of
the component in issue, the intent of the taxpayer in installing
the component, and the effect of removal of the component on the
building), affg. in part and revg. in part 74 T.C. 768 (1980);
Everhart v. Commissioner, 61 T.C. 328, 331 (1973) (moveability
per se does not determine whether or not property is personal
property); Dixie Manor, Inc. v. United States, 44 AFTR 2d 79-
5442, 79-2 USTC par. 9469 (W.D. Ky. 1979) (fact that walls often
are removed because of a change in design by itself is not
sufficient), affd. without published opinion 652 F.2d 57 (6th
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