FPL Group, Inc. v. Commissioner
United States Tax Court
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
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- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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