- 124 - property in issue, no related documents were incorporated by a supply or service contract, and the property generally was not readily identifiable from the related documents, we hold that the fuel assemblies, the nuclear plant property (the MSIV air accumulation system, surveillance system for the heat exchangers, reactor vessel probes, raceway protection, spent fuel equipment, and the area radiation monitoring system equipment), the environmental property (wastewater neutralization treatment system and replacement of PCB transformers), the simulator and training buildings, and the LMS do not qualify as transition property under TRA section 204(a)(3). e. Class Life of Nuclear Fuel Assemblies Pursuant to TRA Section 203(b)(2) Finally, with respect to the ITC claimed for nuclear fuel assemblies placed in service in 1988, 1989, and 1990, we conclude that petitioner is not entitled to those credits even if the fuel assemblies would otherwise qualify as transition property under TRA section 204(a)(3). Congress imposed restrictions on the availability of the ITC for transition property. One of these restrictions is contained in TRA section 203(b)(2), which provides:Page: Previous 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 Next
Last modified: May 25, 2011