Leo and Evelyn Trentadue - Page 15

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               1.  The first factor concerns whether “the property [is]               
          capable of being moved, and has it in fact been moved?”  Whiteco            
          Indus. Inc. v. Commissioner, supra at 672.                                  
          (a) The trellis components comprise posts, stakes, and wires.               
          The posts, which vary in size, are pounded approximately 2 feet             
          into the ground and are secured or stabilized by means of wire and          
          anchors.  After the posts are in place, wire is strung between              
          them, and stakes, clips and other attachment devices are used to            
          attach drip lines and to train the grapevines.  The record in this          
          case reflects that trellising components could be moved; i.e., the          
          wires, anchors, and post can be dismantled and reused.  Respondent          
          made the point, however, that it was not financially practical to           
          move trellis components.  Although respondent may be correct about          
          the financial efficacy and practicality, nevertheless the concept           
          being considered has more to do with the concepts of portability            
          versus permanence.  There was credible testimony on behalf of               
          petitioners that trellising had been moved and reused, and                  
          petitioners’ practice was to store used posts and other trellising          
          components for future use.  Accordingly, as to the trellising,              
          this factor favors petitioners.                                             
               (b) The drip irrigation system comprises pipe, tubing and              
          emitters, risers, and other assorted hardware.  A substantial               
          portion of the pipe is located under the ground.  The portion               
          above the ground (other than the main lines and valves) brings              

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