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substation operated for at least 8 years before petitioner added
the equipment for which it claims an ITC. Because petitioner
operated these substations for several years before the addition
of the items at issue, we conclude that the transformers, not the
entire substations, constitute the plant facilities for purposes
of TRA section 203(b)(1)(C).
Because we find that the equipment at issue, not the entire
substation, constitutes the plant facilities, petitioner had to
commence construction of these items by December 31, 1985. Sec.
49(e); TRA section 203(b)(1)(C). The record reveals that
construction of the items at issue did not begin by December 31,
1985. Mr. Veronee testified that FPL’s procedure generally
requires that both a budget item and an expenditure requisition
receive approval before construction begins. For the items at
issue, all of the expenditure requisitions received approval
after the year 1985. See appendix A (listing the expenditure
133(...continued)
Lindgren Sometime between 1971 and 1973
Miami Lakes Sometime between 1970 and 1972
Milam 1973
Park June 1986
Proctor Nov. 1984
Remsburg May 1984
Rubonia Nov. 1985
Saga June 1981
Southside May 1983
Springtree July 1980
St. Joe 1973
Sweetwater Sometime between 1980 and 1982
Willow Dec. 1982
Winkler June 1986
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