- 170 - 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 receivedPage: Previous 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 Next
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