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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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