- 171 - power using the transmission line systems before the installation of the components at issue. When a unit of property has been placed in service and is available to perform its intended function, component parts added to the unit after it has been placed in service constitute separate pieces of property. See Armstrong World Indus., Inc. v. Commissioner, supra at 434-435. The fact that the transmission line systems received power before petitioner installed these components indicates that the Jensen- Midway-Turnpike and the Andytown-Lauderdale transmission lines functioned properly without the additional components at issue. Instead, the components at issue enhanced the reliability of the Jensen-Midway-Turnpike and the Andytown-Lauderdale transmission lines, helping petitioner meet the growing demand for power.122 122 Mr. Sanders testified: The dispatch of the resources to serve the load changes over time, and the facilities that you would place in service, say, initially to receive the power may not be all that’s required to receive the power forever or through the duration of whatever period of time you plan on buying power. As time marches on, the dynamics of the resources serving the load change. Part of system planning is to continually review the plans that we have for expansion and decide whether or not it’s prudent to add a particular facility at a particular point in time or not. We may think we need A, B, C, D pieces, but we only need A and B to begin with, and part of planning is to continually reevaluate that plan and to decide whether or not you really need C and D * * *Page: Previous 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 Next
Last modified: May 25, 2011