Legal Opinion

FPL Group, Inc. v. Commissioner

United States Tax Court

Decided December 13, 2000No. 5271-96Published

F, a regulated electric utility, is a wholly owned subsidiary of P. F is required to follow prescribed regulatory rules for regulatory accounting and financial reporting purposes. In preparing its consolidated tax returns for the years in issue, P characterized F's expenditures by using the same characterization that F used for regulatory accounting and financial reporting purposes.

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F, a regulated electric utility, is a wholly owned subsidiary of P. F is required to follow prescribed regulatory rules for regulatory accounting and financial reporting purposes. In preparing its consolidated tax returns for the years in issue, P characterized F's expenditures by using the same characterization that F used for regulatory accounting and financial reporting purposes. In an amended petition, P sought to recharacterize as repair expenses, expenditures which it had characterized as capital expenditures for tax purposes. HELD: P's method of accounting for tax reporting purposes…

1Opinion of the Court

FPL GROUP, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

FPL Group, Inc. v. Commissioner

No. 5271-96

United States Tax Court

115 T.C. 554; 2000 U.S. Tax Ct. LEXIS 92; 115 T.C. No. 38;

December 13, 2000, Filed

An appropriate order will be issued granting respondent's motion for partial summary judgment.

F, a regulated electric utility, is a wholly owned

subsidiary of P. F is required to follow prescribed regulatory

rules for regulatory accounting and financial reporting

purposes. In preparing its consolidated tax returns for the

years in issue, P characterized F's…

2Cases cited37 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  3. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  4. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  5. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992

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