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When relocating tanks intact, in addition to the time
required to remove the tanks physically from their original
sites, more time may be needed for one or more of the following
reasons: (1) Internal bracing must be installed before moving
certain tanks intact, which, for a 180-foot diameter tank,
requires 4 to 5 days; (2) building a new concrete ringwall
foundation takes approximately 1 to 2 weeks; (3) the tanks and/or
the terminals may require certain modifications or repairs before
or after installation of the tanks at the new site; and (4) the
new site may be several miles away. We disagree with respondent
that, in our determination of whether the tanks are readily
removable, we should consider the time required for these
additional steps.
In Whiteco, JFM, and similar cases, we limited our
application of this factor to the job of removing the property
from its original site. Indeed, in cases in which we had the
opportunity to incorporate the time required for related
preparatory work, repair work, or travel, we did not do so. See
Standard Oil Co. (Ind.) v. Commissioner, 77 T.C. 349, 372-373,
409 (1981) (excluded travel time when determining whether service
station signs and lighting facilities were readily removable);
Scott Paper Co. v. Commissioner, supra at 172 (focused on how
much time was required to “move” the components rather than how
long it would take to make them “operational” at the new site if
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