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integral to the function of the unit at the time the taxpayer
places the unit in service. Petitioner’s facilities, however,
had been placed in service and produced power without the “wrap
up” work and “enhancements and deficiencies” work, demonstrating
that these items were not essential to the SJRPP’s ability to
produce power when this unit was placed in service.
Similarly, we find that the power plant property in
Consumers Power Co. is distinguishable from petitioner’s “wrap
up” work and “enhancements and deficiencies” work. In Consumers
Power Co., even though the reservoir was used in preoperational
testing, the hydroelectric plant was unable to produce power for
commercial purposes until the testing was completed the following
year. Because the taxpayer in Consumers Power Co. needed both
the reservoir and the pump storage facility to produce power
according to its intended function, the unit was not placed in
service until both components were functional. Here, the SJRPP
Unit 1 and the common facilities were placed in service in 1987,
which was before the completion of the “wrap up” work and
“enhancements and deficiencies” work. As these components were
not necessary, or integral, to the production of power when Unit
1 and the common facilities were placed in service, the “wrap up”
work and “enhancements and deficiencies” work do not qualify as a
single property with Unit 1 and the common facility for purposes
of the self-constructed property transitional rule.
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