FPL Group, Inc. & Subsidiaries - Page 86

                                               - 169 -                                                  
            Alva substation before 1986.  As with the Alva substation, FPL                              
            did not have authorization to construct the other components at                             
            issue as of December 31, 1985.120                                                           
                  Because petitioner did not incur or commit the lesser of $1                           
            million or 5 percent of the construction costs of the property by                           
            December 31, 1985, and did not begin construction as of December                            
            31, 1985, we hold that petitioner is not entitled to an ITC for                             
            the distribution and transmission substation components under the                           
            “self-constructed property” rule.                                                           
                  3.    Transmission Line Systems                                                       
                  Petitioner claims an ITC for costs incurred for the                                   
            components that it added to the Jensen-Midway-Turnpike and the                              
            Andytown-Lauderdale transmission lines.121  With respect to the                             
            Jensen-Midway-Turnpike transmission line, petitioner placed                                 
            property in service with tax bases of $119,911 and $3,109,573 in                            
            the 1989 and 1990 taxable years, respectively.  With respect to                             

                  120 See appendix A, which lists the distribution and                                  
            transmission substation components at issue and the authorization                           
            date as stated on its expenditure request.                                                  
                  121 Specifically, petitioner claims an ITC for the following                          
            components of the Jensen-Midway-Turnpike transmission line: (1)                             
            Turnpike substation--install third-feeder position; (2) Turnpike                            
            substation--add a third 230-kV line terminal; and (3) Crane-                                
            Turnpike 230-kV line--construct a new line.                                                 
                  For the Andytown-Lauderdale transmission line, petitioner                             
            claims an ITC for the following components:  (1) Hiatus-Melaleuca                           
            230-kV line construction; (2) Andytown-Trace 230-kV construction;                           
            (3) Andytown Sub-add 230-kV Lauderdale #4 Terminal; and (4)                                 
            Lauderdale plant-revise relay for 230-kV Andytown.                                          




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