SECTION 1. QUALIFYING
Internal Revenue Bulletin 2013-46 · 2026-10-03 edition · updated 2026-10-04 · United States
ADVANCED COAL PROJECT PROGRAM
Pursuant to § 48A(d)(4), on July 19, 2012, the Internal Revenue Service (the
“Service”) issued Notice 2012–51, 2012–33 I.R.B. 150 (the “Notice”) to establish the § 48A Phase III qualifying advanced coal project program (the “Phase III program”) and to allocate § 48A credits (the “Phase III credits”) in the total amount of $658,500,000. The Notice provides that the credit for a taxable year under the Phase III program is an amount equal to 30 percent of the qualified investment for that taxable year in a qualifying advanced coal project that uses integrated gasification combined cycle technology or other advanced coal-based generation technology. To receive an allocation of the Phase III credits, a qualifying advanced coal project must include equipment that separates and sequesters at least 70 percent of such project’s total carbon dioxide emissions.
Section 48A(d)(5) provides that the Secretary shall, upon making a certification under § 48A(d) or § 48B(d), publicly disclose the identity of the applicant and the amount of the credit certified with respect to such applicant. Section 10.01 of the Notice further provides that the Service intends to publish the results of the Phase III allocation round, and disclose the following information in the event the Phase III credit is allocated to the taxpayer’s project: (a) the name of the taxpayer and (b) the amount of the Phase III credit allocated to the project.
Accordingly, the results of the 2012–13 allocation round under the Phase III program are as follows:
Program Taxpayer Amount of Credit Awarded Total Credit Awarded
Phase III
STCE Holdings, LLC $324,000,000
SCS Energy California, LLC $334,500,000
$658,500,000
The 2012–2013 allocation round is the only allocation round under the Phase III program.
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