I believe that an "expansion" years later would be considered a new installation. And as a new installation it is also eligible to be used for the federal credit.
I probably wouldn't try to push it so far that a tax court might consider the two installations to really be one being artificially and illegitimately split. Tax courts have ruled in other cases to consider "two" transactions to really be one. But frankly you're unlikely to be audited over something like that. And it wouldn't make that much difference in the total tax anyhow, so they probably wouldn't try to argue about it. But IMO I'd just take the approach of "If a dozen people were looking at what I'm doing from the outside - would they come to the same conclusion as I have?"
I probably wouldn't try to push it so far that a tax court might consider the two installations to really be one being artificially and illegitimately split. Tax courts have ruled in other cases to consider "two" transactions to really be one. But frankly you're unlikely to be audited over something like that. And it wouldn't make that much difference in the total tax anyhow, so they probably wouldn't try to argue about it. But IMO I'd just take the approach of "If a dozen people were looking at what I'm doing from the outside - would they come to the same conclusion as I have?"
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