- 21 - 1971), a case in which evidence of “movement” included relocations of floating docks to new sites within the same basin, where they remained “part of the same complex of floating docks”. See also Scott Paper Co. v. Commissioner, 74 T.C. 137, 144-145, 170-171 (1980) (primary electric components relocated within the same facility treated as movable); Moore v. Commissioner, 58 T.C. 1045, 1048, 1052 (1972) (mobile homes relocated within the same park treated as movable), affd. per curiam 489 F.2d 285 (5th Cir. 1973). Even though CITGO has not relocated tanks intact over long distances, the tanks are capable of such movement, contrary to respondent’s contention. In his expert report and at trial, Mr. Watson described tank relocations that he has performed with the tanks intact. Mr. Watson testified that he relocated one tank in Alaska a distance of 55 miles and relocated three tanks in New Zealand approximately 200 miles.17 We also disagree with respondent that the tanks must remain intact when relocated. Respondent does not direct us to, and we are unaware of, any case law establishing such a requirement. Moreover, in JFM, Inc. & Subs. v. Commissioner, supra, the gasoline canopies were dismantled before they were relocated. 17We find unpersuasive respondent’s attempts to distinguish these relocations because they did not occur in the “continental United States”.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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