PDV America, Inc. and Subsidiaries - Page 37

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          would indicate the tanks are to remain there permanently.                   
          Consequently, we conclude that this factor favors petitioner.               
          G.  Conclusion                                                              
               After carefully considering all of the facts and concluding            
          that all six Whiteco factors favor petitioner, we hold that the             
          tanks are not inherently permanent structures.  Accordingly, the            
          tanks are included in asset class 57.0 of Rev. Proc. 87-56, 1987-           
          2 C.B. 686, and treated as 5-year property under section                    
          168(e)(1).                                                                  
               We have considered the remaining arguments of both parties             
          for results contrary to those expressed herein and, to the extent           
          not discussed above, find those arguments to be irrelevant, moot,           
          or without merit.                                                           
               To reflect the foregoing,                                              


                                                  Decisions will be entered           
                                             under Rule 155.                          

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