- 23 - "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 toPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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