Southern California Edison Co. v. Commissioner
United States Tax Court
1. In connection with the construction of Boulder Dam petitioner in 1930 contracted to purchase certain minimum specified amounts of electric power to be generated for a period of about 50 years.
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1. In connection with the construction of Boulder Dam petitioner in 1930 contracted to purchase certain minimum specified amounts of electric power to be generated for a period of about 50 years. As the facts developed it was not required to begin taking such power pursuant to its commitment prior to June 1, 1940. The dam was completed and some generating facilities actually began to produce electric energy in 1936. In late 1936 and early 1937, three cities, Los Angeles, Burbank, and Glendale, which had previously purchased their power at wholesale from petitioner for resale through their…
1Opinion of the Court
OPINION.
Raum, Judge:
In these proceedings petitioner appeals from respondent’s denials in toto of its applications for excess profits tax relief under section 722 of the Internal Revenue Code6 for the years 1942, 1943, 1944, and 1945.
Petitioner was organized in 1909 under California law, and during the intervening years has been engaged as a public utility in generating, transmitting, and distributing electric energy in southern California to domestic, industrial, commercial, and municipal purchasers. Its facilities for generating electricity were in part hydroelectric, or operated by…
2Cases cited13 opinions
- Granite Constr. Co. v. CommissionerUnited States Tax Court · 1952
- National Grinding Wheel Co. v. CommissionerUnited States Tax Court · 1947
- Alison v. United StatesSupreme Court of the United States · 1952
- Irwin B. Schwabe Co. v. CommissionerUnited States Tax Court · 1949
- Homer Laughlin China Co. v. CommissionerUnited States Tax Court · 1946
8 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- The Crowell-Collier Publishing Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Southern California Edison Co. v. CommissionerUnited States Tax Court · 1953