FPL Group, Inc. & Subsidiaries - Page 74

                                               - 158 -                                                  
            a unit of property after the first year that the property was                               
            placed in service do not qualify as being part of the same                                  
            property for purposes of the ITC.116                                                        
                  Petitioner claims an ITC under TRA section 203(b)(1)(B) for                           
            the following items:  (1) The “wrap up” work and “enhancements                              
            and deficiencies” work on Unit 1 and the common facilities at the                           
            SJRPP; (2) distribution and transmission substations; (3) the                               
            integrated transmission line systems at Jensen-Midway-Turnpike                              
            and Andytown-Lauderdale; (4) the “backfit” items at the St. Lucie                           
            nuclear power plant facility; and (5) the spent fuel rack systems                           
            installed at St. Lucie Unit 1 and Turkey Point Unit 4.                                      
                  1.    “Wrap Up” Work and “Enhancements and Deficiencies” Work                         
            at the SJRPP                                                                                
                  Petitioner seeks an ITC under the “self-constructed                                   
            property” rule for costs incurred in the acquisition,                                       
            installation, and construction of the “wrap up” work and                                    
            “enhancements and deficiencies” work at Unit 1 and the common                               
            facilities at the SJRPP during the 1988, 1989, and 1990 taxable                             
            years of $1,702,649, $2,376,238, and -$360,804,117 respectively.                            
            Respondent disagrees.  Respondent argues that petitioner did not:                           
            (1) Incur or commit $1 million or 5 percent of the construction                             


                  116 To the extent that the additional components themselves                           
            constitute separate property that meet the requirements for the                             
            ITC, there could be an ITC for that separate property.                                      
                  117 See supra note 114.                                                               




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