SECTION 3. SPECIAL ALLOCATION

ROUND FOR IGCC PROJECTS USING BITUMINOUS COAL AS A PRIMARY FEEDSTOCK

.01 Except as otherwise specifically provided in this notice, this special allocation round will be conducted in the same manner and under the same procedures as provided under Notice 2007–52 including Appendices A, B, and C. This notice restates or references certain provisions in Notice 2007–52 as a convenience to taxpayers. The restatement or referencing of these provisions does not diminish the effect of provisions that are not restated or referenced.

.02 This special allocation round applies only to the pool of qualifying advanced coal project credit for IGCC projects using bituminous coal as a primary feedstock. The aggregate amount of credits available for allocation from this pool is $133.5 million. The entire $133.5 million is available for allocation in this

[1/ (1 - .02247)], multiplied by 2.5/12) (determined as if no GO Zone additional first year depreciation deduction was claimed for the New Orleans building). Thus, the adjusted depreciable basis of the Hancock building at the time of the like-kind exchange for the Texas building is $3,786,752 (depreciable exchanged basis of $3,888,753, less the depreciation deduction allowable of $80,751 in 2008, less the depreciation deduction allowable of $21,250 in 2009) (determined as if no GO Zone additional first year depreciation deduction was claimed for the New Orleans building).

(iii) For 2009, K decides to use the optional depreciation table to calculate depreciation on the depreciable exchanged basis of the Texas building. Thus, pursuant to § 1.168(i)–6(e)(2)(ii), K ’s depreciation deduction allowable in 2009 for the depreciable exchanged basis of $3,786,752 for the Texas building is $80,746 (the depreciable exchanged basis of $3,786,752 multiplied by the annual depreciation rate of .02564 for the recovery year 3 as modified by the transaction coefficient of 1.0505 [1 / (1 .02247+.02564)], multiplied by 9.5/12).