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(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? * * *
(6) What is the manner of affixation of the
property to the land? * * *
Petitioner's argument that the Reserve Facility is not
inherently permanent rests primarily on evidence that a similar
structure has been moved. Petitioner presented evidence that
R.R. Donnelley & Sons Co. (Donnelley) moved a structure with a
design similar to the Reserve Facility. The evidence shows that
this structure was disassembled, moved approximately 350 feet,
and reassembled. This entire process took approximately 3
months. The relocation of the Donnelley facility did not include
the concrete foundation.
The proper application of the Whiteco factors, however,
rests on the premise that movability itself is not the key
determinant of lack of permanence. See Everhart v. Commissioner,
supra at 331 (holding that movability per se is not determinative
as to whether property is personal or not). Almost any building
or structure can be moved given ample time and manpower. See
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