- 197 - petitioner claims ITCs were placed in service during the 1988, 1989, and 1990 taxable years with tax bases of $3,264,386, $8,091,517, and $4,413,670, respectively. Respondent contends that petitioner failed to introduce written specific plans. In addition, respondent asserts that these substations do not qualify for the plant facility rule because petitioner did not begin construction and did not commit to the construction costs by December 31, 1985. a. Written Specific Plan We find that petitioner satisfies the “written specific plan” requirement of the plant facility transitional rule. Ken Veronee, a substation engineer for FPL, testified that the plot plans showed “the location and the number of the transformers” at the substations. At trial, Mr. Veronee specifically identified the equipment on each plot plan and testified that the equipment for which petitioner seeks an ITC was “within the scope” of the original plan.132 The plot plans consist of diagrams that 132 For the following substations, petitioner introduced the plot plans and Mr. Veronee testified that the transformers and other equipment at issue were included in these plans: Alva substation; Babcock substation; Cedar substation; Court substation; Broward and Crystal substations; Deltona substation; Dumfounding substation; Golden Gate substation; Hollybrook substation; Lakeview substation; Lewis substation; Lindgren substation; Miami Lakes substation; Milam substation; Park substation; Howard and Proctor substation; Remsburg substation; Rubonia substation; Saga substation; Southside substation; Springtree substation; St. Joe substation; Sweetwater substation; Willow substation; and Winkler substation.Page: Previous 187 188 189 190 191 192 193 194 195 196 197 198 199 200 201 202 203 204 205 206 Next
Last modified: May 25, 2011