FPL Group, Inc. & Subsidiaries - Page 113

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                  No doubt, petitioner constructed the SJRPP using extensive                            
            and specific drawings and diagrams.  Yet the plan introduced by                             
            petitioner lacked the specificity necessary to identify the “wrap                           
            up” work and “enhancements and deficiencies” work.  While                                   
            petitioner argues that Mr. Reid linked each work order in issue                             
            to the original written plan, TRA section 203(b)(1)(C) requires                             
            that a taxpayer introduce an actual written plan that                                       
            specifically identifies the items in order to receive the ITC                               
            under the plant facility rule.  Without the “written specific                               
            plan”, we cannot determine whether these items were part of the                             
            plans for the SJRPP as of December 31, 1985, or whether these                               
            specific items result from subsequent plans.                                                
                  We also note that the plan introduced by petitioner is the                            
            seventh revision, dated after December 31, 1985.  The exact date                            
            of the revision is illegible, but it appears to have been made in                           
            1988.  The conference report indicates that insignificant                                   
            modification to the “written specific plan” will not jeopardize                             
            an ITC under the plant facility rule; however, significant                                  
            revisions after December 31, 1985, will disqualify a plant                                  
            facility construction from the relief provided by TRA section                               
            203(b)(1)(C).  H. Conf. Rept. 99-841 (Vol. II), supra at II-57,                             
            1986-3 C.B. (Vol. 4) at 57.  Petitioner failed to prove that                                
            these revisions were insignificant, and Mr. Reid testified that                             
            he did not know whether the revisions were significant.                                     





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