PDV America, Inc. and Subsidiaries - Page 29

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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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