Gulf Power Co. v. Commissioner
United States Tax Court
In 1926 and succeeding years petitioner acquired certain public utility properties in Florida at a cost which was approximately $ 1,700,000 in excess of the cost to the companies which first devoted such properties to public utility purposes. Under the uniform system of accounts subsequently adopted by the Federal Power Commission, petitioner was required to record this excess over original cost in a separate account, 100.5, entitled "Electric Plant Acquisition Adjustments."
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In 1926 and succeeding years petitioner acquired certain public utility properties in Florida at a cost which was approximately $ 1,700,000 in excess of the cost to the companies which first devoted such properties to public utility purposes. Under the uniform system of accounts subsequently adopted by the Federal Power Commission, petitioner was required to record this excess over original cost in a separate account, 100.5, entitled "Electric Plant Acquisition Adjustments." In 1943 the Federal Power Commission ordered the petitioner to charge off approximately $ 1,000,000 of the amount…
1Opinion of the Court
OPINION.
ARUNdell, Judge:
In acquiring its Florida utility properties, petitioner paid approximately $1,700,000 more than the cost of such properties to the companies which first devoted them to utility purposes. This excess over original cost petitioner carried in account 100.5. Petitioner characterizes it as “integration value,” said to be an intangible asset attributable to the advantages and possible economies resulting from integrating many small utility plants and distribution systems into one large system with centrally located generating plants and interconnected power transmission…
2Cases cited5 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Weiss v. WeinerSupreme Court of the United States · 1929
- American Telephone & Telegraph Co. v. United StatesSupreme Court of the United States · 1936
- National Airlines, Inc. v. CommissionerUnited States Tax Court · 1947
3Cited by23 opinions
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- Citizens Federal Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1958
- Equitable Savings & Loan Ass'n v. State Tax CommissionOregon Supreme Court · 1968
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