- 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.Page: Previous 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 Next
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