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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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