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| Headwaters Energy Services engineered, constructed and operated the first, “second
generation” coal-based synfuel facility in 1995.
Headwaters Energy Services also
applied for the first “second generation” PLR (1994),
which was issued to the Company in 1995.
Headwaters Energy Services pioneered work
with the Internal Revenue Service in defining the criteria for chemical
change in coal-based synthetic fuel in 1995 and 1997, and played
a significant role in resolving issues that ultimately resulted in
the IRS issuing Revenue Procedures 2001-30 and 2001-34.
Headwaters Energy Services, along
with other key industry players, has also actively pursued a resolution
to issues stemming from IRS Announcement 2003-46. Headwaters Energy Services developed and commercialized the most widely used proprietary technology utilized in the coal-based synfuel industry. The Headwaters Energy Services Process is the most ruled upon process in the industry having received many Private Letter Rulings (PLRs). Headwaters Energy Services' in-house experts know IRS Section 29 rules and regulations and have continuously worked hand-in-hand with its licensees and other customers to achieve compliance with IRS guidelines. Finally, Headwaters Energy Services engineered, constructed, placed-in-service and operated five synthetic fuel facilities representing an investment in excess of $50 million. |
 Section 29 Background |
