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which is under a “received” stamp. Additionally, the ER bears an
October 3, 1988, date underneath a stamp that reads
“Authorization Certified Accounting Department”. The ER was
revised in early 1989 “to reflect a definitive construction
estimate” and again in early 1991.
With respect to the installation of the MSIV air
accumulation system, petitioner incurred capitalized costs (tax
basis) of $2,846,306 and $126,666, for equipment placed in
service in the 1989 and 1990 taxable years, respectively.
2. Surveillance System for Heat Exchangers
The surveillance system for heat exchangers (surveillance
system) consisted of temperature and flow instruments to ensure
that the heat exchanger, which is designed to remove heat,
performed properly. FPL claims ITCs for the surveillance system
in the 1989 and 1990 taxable years.
On April 15, 1985, FPL responded to a notice of violation
issued by the NRC with respect to its nuclear generating facility
at Turkey Point. One of the corrective steps articulated in the
letter was the “development of a surveillance program”.19
19 Mr. Bible testified that this letter was FPL’s
“commitment to the NRC to perform these modifications and put
this system in place. It’s a written commitment from the
officers of our company to the NRC, requiring us to perform these
actions.”
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