Legal Opinion

Bay State Gas Co. v. Commissioner

United States Tax Court

Decided December 29, 1980No. Docket No. 2987-77PublishedCited by 38 opinions

T is an accrual basis calendar year regulated gas company. Each customer's meter is read bimonthly on an assigned day, and the customer's monthly gas consumption is determined on the basis of the actual reading or estimates for alternate months as of the same day assigned to that customer. T's revenues are accrued monthly as of the meter reading day, in accordance with the "cycle meter reading method of accounting."

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T is an accrual basis calendar year regulated gas company. Each customer's meter is read bimonthly on an assigned day, and the customer's monthly gas consumption is determined on the basis of the actual reading or estimates for alternate months as of the same day assigned to that customer. T's revenues are accrued monthly as of the meter reading day, in accordance with the "cycle meter reading method of accounting." Under this method of accounting, charges for gas consumed between the last meter reading day in December and Dec. 31 are accrued as of the meter reading day in the following…

1Opinion of the Court

Raum, Judge:

The Commissioner determined the following deficiencies in petitioner’s1 income tax;

Year2 Amount

1971 . 3 $14,561.16

1973 . 129,065.78

Petitioner is an accrual basis calendar year public utility engaged in the distribution of gas. It generally bills its customers monthly on the basis of gas consumed as determined by bimonthly meter readings and-estimates for alternate months as of a date corresponding to the bimonthly reading date. Some residential customers, however, elect to be billed in equal monthly installments (budget billing) during the 10-month “heating season” (September…

2Cases cited13 opinions

  1. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  2. Commissioner v. HansenSupreme Court of the United States · 1959
  3. Schulde v. CommissionerSupreme Court of the United States · 1963
  4. United States v. CattoSupreme Court of the United States · 1966
  5. Ft. Howard Paper Co. v. CommissionerUnited States Tax Court · 1967

8 more not listed; retrieve them via the Exa API.

3Cited by38 opinions

  1. Prabel v. CommissionerUnited States Tax Court · 1988
  2. Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
  3. Ansley-Sheppard-Burgess Co. v. CommissionerUnited States Tax Court · 1995
  4. Bank One Corp. v. Comm'rUnited States Tax Court · 2003
  5. Molsen v. CommissionerUnited States Tax Court · 1985

33 more not listed; retrieve them via the Exa API.

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