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power during preoperational testing. Id. at 718. During the
preoperational testing, the unit sustained damage to parts of the
turbine generator and further testing was suspended. Id. at 719.
The repairs were completed in January 1973, and the taxpayer
placed the unit in service later that month. Id. The taxpayer
argued that, even if the entire power plant was not placed in
service in 1972, then the reservoir was placed in service in 1972
when it was used in testing. Id. at 725. The Court found that
the pump storage plant and the reservoir comprised a single unit
of property because each item operated simultaneously and both of
these components were necessary to produce electrical power. Id.
at 726. The Court concluded that the plant was placed in service
in 1973, when it was ready to produce power. Id.
With respect to petitioner’s property, the SJRPP Unit 1 and
the common facilities were placed in service on March 27, 1987,
while the “wrap up” work and “enhancements and deficiencies” work
were placed in service during the 1988, 1989, and 1990 taxable
years.
Unlike Haw. Indep. Refinery, Inc., where the tanker-mooring
facility, refinery, and pipelines were necessary to operate the
unit, Unit 1 and the common facilities at the SJRPP were placed
in service and commercially operational before petitioner
completed the “wrap up” work and “enhancements and deficiencies”
work. To be considered a single property, the components must be
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