- 32 -
relocation but is silent as to the amount of time required to
remove a tank using that method. The record does show that with
the dismantling and reconstruction method described in API
Standard 653, a crew can remove the tank in about 1 week.
Although the removal of tanks with these methods has the
potential to require more time and larger crews than the removal
of other types of property at issue in past cases, we do not
think that the time and crew requirements for removing tanks are
too substantial. Moreover, petitioner has demonstrated that it
is possible to remove tanks in a relatively short amount of time.
We also cannot agree with respondent that the complex procedures
for removing tanks, which are carried out by professionals
familiar with the technology, render the job too substantial.
On the basis of the foregoing, this factor favors
petitioner.
E. How Much Damage Will the Property Sustain Upon Its Removal?
In Whiteco Indus., Inc. v. Commissioner, 65 T.C. at 673, we
observed that “much” of an outdoor advertising sign was not
damaged upon its removal. We also noted that a sign’s removal
generated no wastage, except for the portion of the poles
surrounded by concrete, and, if the sign was removed at the end
of an advertising contract, the sign face was replaced. Id.
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 NextLast modified: May 25, 2011