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or clubhouse. * * * [H. Rept. 1447, 87th Cong., 2d
Sess. (1962), 1962-3 C.B. 405, 516; emphasis added.]
In light of Congress' expressed intentions, and because we
find that the Reserve Facility functions essentially as a
warehouse and the human activity involved therein is not merely
incidental, we hold that the Reserve Facility is a building.
Petitioner contends that even if the Reserve Facility
resembles a building and functions as a building, it is not an
improvement to land because it is movable. In cases involving
the issue of movability, we have approached the question of
whether the property was tangible personal property by
determining whether the structure was "inherently permanent".
Moore v. Commissioner, 58 T.C. 1045, 1052 (1972), affd. 489 F.2d
285 (5th Cir. 1973); Fox Photo, Inc. v. Commissioner, T.C. Memo.
1990-348. Whether property is inherently permanent depends upon
the fashion in which it is affixed to the land and whether it is
designed to remain permanently in place. Everhart v.
Commissioner, 61 T.C. 328, 330 (1973). In making our
determination as to whether the Reserve Facility is inherently
permanent, we shall consider the six-part test articulated in
Whiteco Industries, Inc. v. Commissioner, 65 T.C. 664, 672-673
(1975):
(1) Is the property capable of being moved, and
has it in fact been moved? * * *
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