Common Contracts
1 similar Power Purchase Agreement contracts
Internal Revenue Senice index Number:Power Purchase Agreement • August 27th, 2022
This responds to Taxpayer’s request for a private letter ruling dated February 12, 1998. Specifically, Taxpayer has requested a ruling that the termination of Taxpayer’s power purchase agreement pursuant to the Agreement constitutes or involuntary conversion” of its PPA within the meaning of 1033 and 123 1 Internal Revenue Code (“Code”). Taxpayer has also requested a ruling that the amount of any gain (or loss) required to be recognized by Taxpayer in connection with the conversion of PPA is a gain or 1231 loss. Taxpayer also requests rulings that the amounts paid to terminate certain agreements relating to its facility are deductible under 162 or 163 in the year paid.
