- 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 NextLast modified: May 25, 2011