- 191 - however, petitioner failed to introduce any drawings detailing the “backfit” items. Because the construction plans for St. Lucie Units 1 and 2 lacked the precise detail necessary to identify the “backfit” items, these plans fail to satisfy the requirements of the plant facility rule. While TRA section 203(b)(1)(C) requires a “specific” plan, petitioner’s plot plan neither specifically identifies any of the “backfit” items nor identifies the location of these items at St. Lucie nuclear plant. Although Mr. Paduano testified that petitioner has specific drawings for these items, petitioner failed to introduce these drawings into evidence. Absent written plans that precisely and unambiguously identify the “backfit” items, we hold that petitioner’s plot plan lacks the specificity required by TRA section 203(b)(1)(C). The underwater intrusion system, the condensate polisher tie line, and the instrument air system upgrade do not qualify as transition property under TRA section 203(b)(1)(C). 2. “Wrap up” Work and “Enhancements and Deficiencies” Work at the SJRPP Petitioner contends that the SJRPP “wrap up” work and “enhancements and deficiencies” work qualify for the plant facility rule of TRA section 203(b)(1)(C). This property was placed in service during the 1988, 1989, and 1990 taxable years with tax bases of $1,702,649, $2,376,238, and ($360,804), respectively. Respondent argues that the SJRPP items do notPage: Previous 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 200 Next
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