FPL Group, Inc. & Subsidiaries - Page 206

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                                    (C) Class lives.--For purposes of                                   
                              subparagraph (A)--                                                        
                                          (i) the class life of property to                             
                                    which section 168(g)(3)(B) of the                                   
                                    Internal Revenue Code of 1986 (as added                             
                                    by section 201) shall be the class life                             
                                    in effect on January 1, 1986, except                                
                                    that computer-based telephone central                               
                                    office switching equipment described in                             
                                    section 168(e)(3)(B)(iii) of such Code                              
                                    shall be treated as having a class life                             
                                    of 6 years,                                                         
                                          (ii) property described in section                            
                                    204(a) shall be treated as having a                                 
                                    class life of 20 years, and                                         
                                          (iii) property with no class life                             
                                    shall be treated as having a class life                             
                                    of 12 years.                                                        
                                    (D) Substitution of applicable dates.--                             
                              If any provision of this Act substitutes a                                
                              date for an applicable date, this paragraph                               
                              shall be applied by using such date.                                      
                  The pertinent portion of TRA section 204, 100 Stat. 2146,                             
            provides:                                                                                   
                  SEC. 204. ADDITIONAL TRANSITIONAL RULES.                                              
                        (a) Other Transitional Rules.--                                                 
                             *     *     *     *     *     *     *                                      
                              (3) Supply or service contracts.--The                                     
                        amendments made by section 201 shall not apply to                               
                        any property which is readily identifiable with                                 
                        and necessary to carry out a written supply or                                  
                        service contract, or agreement to lease, which was                              
                        binding on * * * [December 31, 1985] March 1,                                   
                        1986.                                                                           
                  We note that “provisions granting special tax exemptions are                          
            to be strictly construed.”  Helvering v. Nw. Steel Rolling Mills,                           





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