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are incorporated herein by this reference. Petitioner’s
principal place of business was in North Palm Beach, Florida,
when its petition was filed.
Petitioner is the parent corporation of a publicly traded
holding company that filed consolidated Federal income tax
returns on a calendar year basis for its 1988 through 1992
taxable years. FPL is a first-tier, wholly owned subsidiary of
petitioner with operations throughout most of the east and lower
west coasts of the State of Florida and is a member of the
consolidated group. As a public utility, FPL is subject to
regulation by various State and Federal agencies, including the
Florida Public Service Commission (FPSC), the Federal Energy
Regulatory Commission (FERC), and the Nuclear Regulatory
Commission (NRC).
To generate electricity, FPL operates nuclear and nonnuclear
power plants. FPL owned and operated four nuclear electric
generating units, named: St. Lucie Unit 1, which was operational
commencing in 1976; St. Lucie Unit 2, which was operational
commencing in 1983; Turkey Point Unit 3, which was operational
commencing in 1972; and Turkey Point Unit 4, which was
operational commencing in 1973.
During the years at issue, FPL was under the jurisdiction of
the FPSC, which regulated and supervised the rates charged by and
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