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Petitioner argues that the “wrap up” work and “enhancements
and deficiencies” work serve no function on their own, and
therefore, constitute a single unit of property with SJRPP Unit
1. We find it irrelevant that these components have no
independent purpose because Unit 1 and the common facilities at
the SJRPP were already placed in service and performed their
designed function without these components. When Unit 1 and the
common facilities were placed in service, these items formed a
complete unit that served the intended purpose of producing
power; these components functioned without the “wrap up” work and
“enhancements and deficiencies” work. See Consumers Power Co. v.
Commissioner, supra at 725. While the “wrap up” work and
“enhancements and deficiencies” work might be necessary to the
production of power at the SJRPP at some date in the future,
these components were not essential on the date Unit 1 and the
common facilities were placed in service.
Because the SJRPP Unit 1 and the common facilities were
placed in service and produced power in a year before the “wrap
up” work and “enhancements and deficiencies” work was completed,
we conclude that these latter components constitute separate
property. Petitioner makes no argument that the “wrap up” work
and “enhancements and deficiencies” work qualify as self-
constructed property independently from the SJRPP Unit 1 and the
common facilities. As a result, petitioner has not shown that it
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