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3. MetroVision’s Activities Pursuant to the Franchise
MetroVision commenced construction of the Livonia cable
system in 1984. By 1985, construction was substantially
complete. During the 1988-90 period, the construction activity
undertaken by MetroVision was to (1) extend the cable system into
newly constructed subdivisions, (2) deliver service to new
customers in existing service areas, and (3) replace worn out,
broken, or otherwise obsolete cable television equipment.
Respondent does not dispute, and we find, that those activities
were required by and undertaken pursuant to the terms of the
Livonia Franchise Agreement. No significant changes to the
system, in terms of the number of channels or the channel
selection, were undertaken during the 1988-90 period.
Petitioner has been unable to locate the invoices, purchase
orders, or any other list of the items of property placed in
service during the audit years for which it is claiming
transition ITC (the subject property). As a result, petitioner
has been unable to demonstrate that the subject property is
property described in the Livonia Franchise Agreement. The
parties have stipulated, however, as to the authenticity of
certain charts of accounts and general ledger materials
pertaining to MetroVision which show, by dollar amount and
general category of expenditure (e.g., "Distribution System",
"Head End Equipment", "Local Production Equipment", "Traps &
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