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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.
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