Newhouse Broadcasting Corp. and Subsidiaries, et al. - Page 23




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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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