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the Andytown-Lauderdale transmission line, petitioner placed
property in service with tax bases of $6,436,912, $545,188, and
$16,707 in 1988, 1989, and 1990 taxable years, respectively.
Petitioner claims that these transmission lines were essential
components to the Jensen-Midway-Turnpike and Andytown-Lauderdale
substations; therefore, the costs incurred and construction date
requirements of TRA section 203(b)(1)(B) must be analyzed from
the perspective of the transmission line system.
Respondent argues that the transmission line components
constitute separate property from the transmission line system.
As a separate property, respondent asserts that petitioner failed
to incur or commit any costs before January 1, 1986, and that the
construction of these components had not begun before that date.
We agree with respondent.
Components will constitute a single property when all parts
are functionally interdependent and essential to the operation of
the unit as a whole when the unit becomes operational. Armstrong
World Indus., Inc. v. Commissioner, 974 F.2d at 434; Haw. Indep.
Refinery, Inc. v. United States, 697 F.2d at 1069; Consumers
Power Co. v. Commissioner, 89 T.C. at 726. We find that the
Jensen-Midway-Turnpike and the Andytown-Lauderdale transmission
line components constitute separate property.
Unlike Haw. Indep. Refinery, Inc., where the refinery’s
function depended on the offsite components, petitioner received
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