- 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.Page: Previous 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 Next
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