CCA 201302017 (Nov. 28, 2012)

(mobile billboards constitute tangible personal property that qualify for I.R.C. Sec. 199 deduction, but traditional and modern billboards are real property (inherently permanent structure) not qualified for I.R.C. Sec. 199; under facts of CCA, taxpayer installed traditional and modern billboards on leased land with leases ranging from 30 days to 20 years and leases continued until billboards no longer profitable; mobile billboards relocated on frequent basis; mobile billboard attached to truck that is moved to various locations; traditional billboard attached to wooden pole; modern billboard attached to steel frame attached to steel poles; mobile billboard not attached to real property and not intended to remain stationary indefinitely; traditional billboard an inherently permanent structure; modern billboard inherently permanent structure).