Marta, a lover of early twentieth-century American history and architecture, discovers a 1920s house in a downtown district of Atlanta during a recent visit. She decides not only to purchase and renovate this particular home, but also to move the structure to her hometown of Manhattan, Kansas, so her community can enjoy its architectural features. She moves the entire house to Manhattan, renovates it, and reduces her tax liability by the rehabilitation expenditures credit. It takes her approximately a year to complete the project. Her rehabilitation expenditures include the costs associated with renovation ($30,000) and the moving expenses ($10,000) incurred to relocate the house. The IRS disallows the credit because she moved the building. Furthermore, the IRS contends the moving expenses are not qualified rehabilitation expenditures. Who will prevail in court?