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The franchises, tariffs, and contracts in Bell Atl. Corp.
failed to specifically refer to the taxpayer’s property. The
statutes and regulatory guidance petitioner relies on also fail
to specifically identify any of FPL’s property. These regulatory
materials establish quality and service standards and lack
references or descriptions that specifically relate to
petitioner’s property. We find that the documents lack the
specifications and amounts necessary to readily identify
petitioner’s property for purposes of TRA section 204(a)(3).
ii. Correspondence
In addition to the statutes and regulatory guidance,
petitioner asserts that numerous items of correspondence are
“related documents” that readily identify the property in issue.
Particularly, petitioner relies on: (1) Letter No. L-85-385,
dated October 11, 1985, from FPL to the Office of Nuclear Reactor
Regulation; (2) a letter dated July 18, 1986, from FPL to the
Office of Nuclear Reactor Regulation; and (3) Letter No. L-86-296
dated December 5, 1986, from the Nuclear Regulatory Commission
(NRC) to Mr. C.O. Woody, group vice president of FPL’s nuclear
energy department.
FPL submitted to the NRC Letter No. L-85-385, which
contained attachments relating to the requirements of appendix R.
Attachment 1 states that FPL must install the following equipment
at Turkey Point Unit 4:
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