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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:
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