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specifically depict and locate the transformers at the
distribution and transmission substations.
Respondent asserts that petitioner does not satisfy the
“written specific plan” requirement because the “diagrams
submitted by FPL included revisions after December 31, 1985.” We
disagree with respondent. As we noted, the conference report
indicates that a taxpayer may modify the written plan as long as
the modifications are not significant. H. Conf. Rept. 99-841
(Vol. II), supra at II-57, 1986-3 C.B. (Vol. 4) at 57. Mr.
Veronee testified that the revisions made after December 31,
1985, reflect the original design for each substation. Because
these modifications adhere to the original design, we believe
that they are insignificant and allowable under TRA section
203(b)(1)(C).
Although Mr. Veronee testified that the Hiatus substation
plot plan would have contained information similar to that in the
other plot plans, petitioner did not introduce the plot plan for
this substation. As a result, petitioner does not satisfy the
“written specific plan” requirement for the Hiatus substation.
For the remaining substations at issue, the plot plans satisfy
the “written specific plan” requirement of TRA section
203(b)(1)(C) because the plans provide written diagrams of the
substations and specifically identify the equipment that
petitioner constructed.
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