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under TRA section 203(b)(1)(B) because Unit 2 was placed in
service before FPL built the condensate polisher tie line.
We disagree with petitioner, and find that the tie line
constitutes separate property. Although a condensate polisher is
necessary to prevent excessive corrosion in the steam generator,
St. Lucie Unit 2 was placed in service and operated without the
tie line system. Petitioner operated St. Lucie Unit 2 while it
conducted a study to determine the best method for preventing
corrosion, demonstrating that St. Lucie Unit 2 had an independent
function before the completion of the condensate polisher tie
line property in issue. See Armstrong World Indus., Inc. v.
Commissioner, supra at 435-436. Petitioner states that the tie
line was placed in service in 1989 and 1990. The parties
stipulate that St. Lucie Unit 2 was operational in 1983. Unlike
Haw. Indep. Refinery, Inc., where the oil refinery facility could
not perform its function without the pipelines and the tanker-
mooring facility, St. Lucie Unit 2 produced power years before
the installation of the condensate polisher tie line.
Petitioner’s condensate polisher tie lines are
distinguishable from the “Corporate Development Center” in
Steelcase, Inc. v. United States, supra. In Steelcase, the
design modification took place during the construction of the
building, which had not been placed in service. In this case,
petitioner built St. Lucie Unit 2, placed it in service, and then
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