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stipulated that a series of ERs were used by FPL to authorize
amounts to be spent on the SJRPP.73
With respect to the installation of equipment at the SJRPP,
petitioner incurred capitalized costs (tax basis) of $1,702,649,
$2,376,238, and ($360,804) for equipment placed in service in the
1988, 1989, and 1990 taxable years, respectively.
H. The Southern Company Contracts
On October 18, 1979, FPL entered into an interchange
contract with an affiliated group of corporations providing
electric power in several southeastern States, including Georgia
(collectively referred to as the Southern companies). The
interchange contract enabled FPL to acquire coal-fired power from
the Southern companies. An “interconnection” between power
companies links the two companies’ systems to enable them to
purchase, sell, and exchange power. Before 1979, FPL did not
have any interconnections with the Southern companies.
73 For simplicity, the following list identifies these ERs
and the respective amounts authorized: (1) ER No. 6473, $1,900;
(2) ER No. 6477, $7,300; (3) ER No. 6483, $105,400; (4) ER No.
6487, $96,500; (5) ER No. 6609, $22,400; (6) ER No. 6638,
$35,000; (7) ER No. 6631, $8,900; (8) ER No. 6640, $14,600; (9)
ER No. 6627, $3,100; (10) ER No. 6629, $1,000; (11) ER No. 6645,
$4,400; (12) ER No. 6623, $2,500; (13) ER No. 6633, $14,300; (14)
ER No. 6637, $8,800; (15) ER No. 6639, $38,400; (16) ER No. 6642,
$16,800; (17) ER No. 6651, $9,800; (18) ER No. 6653, $11,200,
revised to $116,000; (19) ER No. 6611, $21,800; (20) ER No. 6654,
$2,200; (21) ER No. 6722, $9,600; (22) ER No. 6716, $2,500; (23)
ER No. 6728, $6,600; (24) ER No. 6730, $11,700; and (25) ER No.
6644, $9,200.
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