Legal Opinion

Indianapolis Power & Light Co. v. Commissioner

United States Tax Court

Decided April 20, 1987No. Docket No. 925-82Published

P, a regulated utility primarily engaged in the business of selling electricity to residential and commercial customers, required uncreditworthy customers to deposit funds which were refunded upon termination of service or upon P's determination that the customer met certain creditworthiness standards. A customer generally retained the right to determine whether his deposit would be returned to him or credited against his account.

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P, a regulated utility primarily engaged in the business of selling electricity to residential and commercial customers, required uncreditworthy customers to deposit funds which were refunded upon termination of service or upon P's determination that the customer met certain creditworthiness standards. A customer generally retained the right to determine whether his deposit would be returned to him or credited against his account. The deposits were in fact generally credited against an account, and the remainder was returned by check. Held, the deposits received by P were security deposits,…

1Opinion of the Court

Indianapolis Power & Light Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Indianapolis Power & Light Co. v. Commissioner

Docket No. 925-82

United States Tax Court

88 T.C. 964; 1987 U.S. Tax Ct. LEXIS 52; 88 T.C. No. 52;

April 20, 1987; As amended May 4, 1987 April 20, 1987, Filed

Decision will be entered under Rule 155.

P, a regulated utility primarily engaged in the business of selling electricity to residential and commercial customers, required uncreditworthy customers to deposit funds which were refunded upon termination of service or upon P's determination that the customer…

2Cases cited25 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  4. Schulde v. CommissionerSupreme Court of the United States · 1963
  5. BJR Corp. v. CommissionerUnited States Tax Court · 1976

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