PDV America, Inc. and Subsidiaries - Page 30

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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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