- 29 - not readily removable due to the amount of time required to complete the relocation process; the height, weight, and width limitations related to transporting tanks on highways or across waterways; and the complexity of the relocation procedures. In Whiteco Indus., Inc. v. Commissioner, supra at 673, we described the disassembly and removal of the taxpayer’s outdoor advertising signs as a “relatively quick and easy process.” Although the record in Whiteco did not indicate the full amount of time required to complete the process, we concluded that, on the basis of the known time and effort involved, the signs were readily removable. Id.; see also Film N’ Photos, Inc. v. Commissioner, T.C. Memo. 1978-162 (photo merchandising units could be removed “in a relatively short time”). With respect to the gasoline canopies in JFM, Inc. & Subs. v. Commissioner, T.C. Memo. 1994-239, although we acknowledged that the components were “collectively formidable”, we observed that the canopies could be erected or dismantled and moved in a few days.20 We also noted that the gasoline canopies had in the past been dismantled, modified, and reinstalled or sold to third parties. Id. 20Specifically, a gasoline canopy could be installed by a crew of four in 3 days and dismantled by a crew of three in 2 days. JFM, Inc. & Subs. v. Commissioner, T.C. Memo. 1994-239.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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