FPL Group, Inc. & Subsidiaries - Page 123

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            requisition approval dates).  We find that petitioner failed to                             
            begin construction by December 31, 1985, as required by the plant                           
            facility transitional rule.                                                                 
                        c.    Costs Committed or Incurred                                               
                  Even assuming arguendo that petitioner had commenced                                  
            construction as required by TRA section 203(b)(1)(C), we agree                              
            with respondent that FPL failed to incur or commit to the                                   
            construction costs by December 31, 1985.  TRA section                                       
            203(b)(1)(C) requires that “more than one-half of the cost of                               
            such * * * facility has been incurred or committed by” December                             
            31, 1985.  See sec. 49(e).                                                                  
                  Petitioner asserts that it had committed to 100 percent of                            
            the construction costs, as evidenced by the plot plan.  We                                  
            disagree.  We think that the plain meaning of “committed”, as                               
            used in TRA section 203(b)(1)(C), requires that a taxpayer                                  
            contract for, or be obligated to, the construction of the                                   
            property.  See Webster’s Third New International Dictionary 457                             
            (1986) (defining “commit” as to “contract or bind by obligation                             
            to a particular disposition”).                                                              
                  Although the plot plans provide for additional transformers                           
            that petitioner may install in the future, Mr. Veronee testified                            
            that the plans did not mandate that petitioner construct these                              
            additional items.  Mr. Veronee further testified that petitioner                            







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