Priv. Ltr. Rul. 201035003 (May 19, 2010)

(gain from sale of renewable energy credits under state program by state resident included in resident's income; full I.R.C. Sec. 25D credit not available for purchase of qualified solar electric property because credit not available for expenditure to extent of the amount excluded as a subsidy under I.R.C. Sec. 136(a)).