Prompt: Draft a formal IRS Appeals protest based on the attached Letter 106C disallowing my client's full deduction for her residential solar energy system under IRC section 25D. Specifically, ensure that you discuss why the the battery storage unit meets the definition of a qualified battery storage technology expenditure under IRC section 25D(d)(6). Ensure you follow the instructions for a formal protest on page 2 of the attached Letter 106C. Below is some factual context to include in the letter: Jane Smith, a single filer for the 2022 tax year, claimed a $50,485 Residential Clean Energy Property Credit on her timely filed Form 1040 (via Form 5695) for that year. She claimed a credit for 30% of her $70,154 solar photovoltaic system ($21,046) and 30% of her $98,130 integrated battery storage unit ($29,439). When the IRS requested more information, she submitted contractor invoices, a manufacturer certification that the battery is charged solely by the solar array, proof of payment, and time-stamped installation photos. Nonetheless, on August 8, 2023, the IRS issued Letter 106C allowing only the $21,046 solar credit and disallowing the $29,439 battery credit, erroneously concluding it did not qualify under IRC section 25D.
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