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We glean from this that the specifications and amount of
property must be readily or “easily” ascertainable from the terms
of the source documents, which consist of the contract and
related documents. United States v. Commonwealth Energy Sys.,
supra at 16; Bell Atl. Corp. v. United States, supra at 224.
Because the specifications and amount of the property must be
readily ascertainable, this rule requires a “specific, although
not exact”, inquiry. United States v. Commonwealth Energy Sys.,
supra.
1. Property Purchased and/or Installed Pursuant to the
Tariff
Petitioner argues that “FPL and its customers, through the
* * * [FPSC], entered into a binding written supply or service
contract in the form of a Tariff in 1984.” Petitioner further
contends that the tariff is a contract under Florida law;
therefore, it is a binding contract for Federal tax purposes.
Accordingly, petitioner asserts that it acquired, installed, and
constructed and/or reconstructed property that was readily
identifiable within the tariff and/or related documents, and that
this property was necessary to carry out FPL’s supply obligations
to its customers under the tariff. Petitioner seeks ITCs for the
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