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"specifically described" is the applicable standard for
determining entitlement to transition ITC in this case, as argued
by respondent, we find that such standard is satisfied in the
pre-1986 documents.
Petitioner has been unable to furnish "any documents
contemporaneous with * * * [the audit years], such as equipment
invoices, purchase orders, or budget approval documents * * * to
provide an itemized identification of the alleged Transitional
Property." However, we do not consider petitioner’s inability,
to date, to specifically identify the subject property as grounds
for granting respondent’s motion. The general categories of
expenditures for equipment described in MetroVision’s charts of
account and general ledger materials for the audit years (which
we accept as accurate only for purposes of respondent’s motion)
are consistent with the descriptions of equipment contained in
the pre-1986 documents. Therefore, we cannot conclude, as a
matter of law, that the subject property (as represented in
MetroVision’s charts of account and general ledger materials) is
not "specifically described" in such documents. We also conclude
that even updated versions of the equipment described in the pre-
1986 documents that petitioner acknowledges were installed in the
Livonia cable television system during the audit years may be
said to be "specifically described" in and, therefore, "readily
identifiable with" such documents in light of the requirement to
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