FPL Group, Inc. & Subsidiaries - Page 70

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            component parts constitute a single piece of property when the                              
            components are interdependent, essential, and integral to the                               
            operation of a unit at the time it is placed in service.  Id.;                              
            Haw. Indep. Refinery, Inc. v. United States, supra at 1069;                                 
            Consumers Power Co. v. Commissioner, supra at 725-726.  For                                 
            purposes of the ITC, the components that make up a unit on the                              
            date that the property is operational and placed in service                                 
            constitute a single unit of property, even though additional                                
            components may be necessary in the future for the unit to                                   
            continue to function properly.  These additional components would                           
            constitute separate property.  See Armstrong World Indus., Inc.                             
            v. Commissioner, supra at 434, 436.                                                         
                  Petitioner argues that components that are added to property                          
            in years subsequent to the year the property is placed in service                           
            can be considered part of the same property for purposes of the                             
            ITC.  Petitioner argues that section 1.46-3(d)(4), Income Tax                               
            Regs., allows property to qualify for an ITC in “‘portions’ from                            
            one year to the next, as construction continues and the remainder                           
            of the functionally integrated components * * * are completed and                           
            placed in service.”                                                                         
                  Section 1.46-3(d)(4)(i), Income Tax Regs., allows an ITC                              
            under section 38 “only for the first taxable year in which such                             
            property is placed in service by the taxpayer.”  Section 1.46-                              
            3(d)(4)(i), Income Tax Regs., provides:                                                     





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