- 10 - 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 &Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011