- 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 NextLast modified: May 25, 2011