Pacific Enters. & Subsidiaries v. Commissioner
United States Tax Court
P was the parent company of several public utility gas companies, including S and S1. S and S1 owned pipelines and underground storage reservoirs. S and S1 maintained a static volume of gas in the pipelines and reservoirs that provided the pressure needed to deliver gas to customers. S and S1 accounted for these pressurizing gases ("cushion gas" in reservoirs and "line pack gas" in pipelines) as capital assets.
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P was the parent company of several public utility gas companies, including S and S1. S and S1 owned pipelines and underground storage reservoirs. S and S1 maintained a static volume of gas in the pipelines and reservoirs that provided the pressure needed to deliver gas to customers. S and S1 accounted for these pressurizing gases ("cushion gas" in reservoirs and "line pack gas" in pipelines) as capital assets. R determined that these gases should be accounted for as inventory. In 1985 and 1986, S reclassified a portion of its working gas to cushion gas, based on engineering reports that more…
1Opinion of the Court
Pacific Enterprises and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Pacific Enters. & Subsidiaries v. Commissioner
Docket No. 5295-91
United States Tax Court
101 T.C. 1; 1993 U.S. Tax Ct. LEXIS 42; 101 T.C. No. 1;
July 12, 1993, Filed
Decision will be entered under Rule 155.
P was the parent company of several public utility gas companies, including S and S1. S and S1 owned pipelines and underground storage reservoirs. S and S1 maintained a static volume of gas in the pipelines and reservoirs that provided the pressure needed to deliver gas to customers. S and S1…
2Cases cited27 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Casey v. CommissionerUnited States Tax Court · 1962
- Coors v. CommissionerUnited States Tax Court · 1973
- Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
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