PDV America, Inc. and Subsidiaries - Page 21

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          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.           
               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”.                                                             

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