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Although the term "facility" appears over 100 times in the Code and over 200 times in the regulations, nowhere is it defined. A recent revenue ruling, which addresses a relatively obscure energy tax credit, finally provides some useful guidance on the meaning of the term.
Rev. Rul. 94-31 considers Sec. 45, enacted by the Energy Policy Act of 1992, which provides a production credit for facilities placed in service after Dec. 31, 1993. In the ruling, the taxpayer had placed a...