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a tax basis of $338,665. The condensate polisher tie line was
placed in service during the 1989 and 1990 taxable years with tax
bases of $3,826,317 and $388,906, respectively. The instrument
air upgrade property was placed in service during the 1988, 1989,
and 1990 taxable years with tax bases of $1,541,721, $1,717,941,
and $316,912, respectively. Respondent argues that petitioner
fails to satisfy the written specific plan requirement because
the one-page plot plan does not specifically identify the
“backfit” items at the St. Lucie Units 1 and 2. We conclude
that petitioner failed to introduce a “written specific plan” for
the “backfit” items. Although the parties stipulate that the
one-page plot plan constituted construction plans for the St.
Lucie Units 1 and 2, petitioner has failed to prove that the plan
satisfies the specificity required by TRA section 203(b)(1)(C).
Mr. Paduano, a retired FPL manager,130 testified that the
construction plan identifies “the top view of the power plant
showing the major buildings and some of the major equipment and
the general layout locations of those equipments and buildings”;
however, he further testified that this document does not
specifically identify the “backfit” items at issue. Mr. Paduano
testified that petitioner constructed St. Lucie Units 1 and 2
using “tens of thousands of drawings for this site plan”;
130 Mr. Paduano worked on a “broad area of projects”,
primarily resolving “technical issues and plan modifications and
backfit.”
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