- 154 - 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:Page: Previous 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 Next
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