FPL Group, Inc. & Subsidiaries - Page 81

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            committed or incurred by December 31, 1985, the lesser of $1                                
            million or 5 percent of the cost of property consisting of the                              
            “wrap up” work and “enhancements and deficiencies” work and                                 
            therefore does not meet the requirements of TRA section                                     
            203(b)(1)(B).                                                                               
                  TRA section 203(b)(1)(B) also requires that a taxpayer had                            
            to begin construction of the property for which it seeks an ITC                             
            by December 31, 1985.  The conference report clarifies when                                 
            construction begins for purposes of TRA section 203(b)(1)(B).                               
            Construction of a facility or equipment begins when “physical                               
            work of a significant nature starts.”  H. Conf. Rept. 99-841                                
            (Vol. II), supra at II-56, 1986-3 C.B. (Vol. 4) at 56.  “Physical                           
            work does not include preliminary activities such as planning or                            
            designing, * * * researching, or developing.”  Id.  When the                                
            property at issue is a building, “‘property’ includes all of the                            
            normal and customary components that are purchased from others                              
            and installed without significant modification”.  Id.  As we have                           
            previously held, petitioner cannot meet this requirement by                                 
            treating the “wrap up” work and “enhancements and deficiencies”                             
            work as one property with Unit 1 and the common facilities at                               
            SJRPP.                                                                                      
                  Mr. Reid testified that “ER4110 was the ER that was opened                            
            as the wrap ER * * * to do the remaining construction items under                           
            unit 1 and common [facility].”  This ER was first authorized on                             





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