PDV America, Inc. and Subsidiaries - Page 31

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          2 months of preparatory work had not been performed ahead of                
          time); Fox Photo, Inc. v. Commissioner, T.C. Memo. 1990-348                 
          (excluded the time required to restore the old site to its                  
          original condition and to repair and refurbish the 1-hour photo             
          labs for reuse and, instead, focused on time required to remove             
          the labs from their location).  Because the consideration of                
          travel time is not appropriate for this factor, we also decline             
          to consider the height, weight, and width restrictions that may             
          arise when transporting the tanks on certain roads or over                  
          certain waterways.                                                          
               The record is not entirely clear with respect to the amount            
          of time required for removal of the tanks using the various tank            
          relocation methods.  For example, the 1- to 2-week time estimate            
          for moving tanks with the hovercraft technology includes time               
          spent on work to make the tanks operational at the new site.  As            
          demonstrated by CITGO’s relocation of East Chicago tank No. 44,             
          however, when the hovercraft technology is properly used, small             
          to medium size tanks can be removed from their original sites in            
          approximately 4 hours, a shorter amount of time than the 2 days             
          required to remove the gasoline canopies in JFM, Inc. & Subs. v.            
          Commissioner, supra, and the 12 to 18 hours required to remove              
          the 1-hour photo labs in Fox Photo, Inc. v. Commissioner, supra.            
          Similarly, for the Watson Air Bag technology, the record                    
          indicates that crews will require about 1 week for the entire               

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