Orange & Rockland Utilities, Inc. v. Commissioner
United States Tax Court
Petitioners, regulated public utility companies, reported income on an accrual calendar year basis. Petitioners employed the cycle meter reading method of accounting for tax purposes. Consequently, revenue generated for utility services furnished after the last cycle meter reading date in December was not accrued until after the close of the taxable year. Expenses related to such utility services were deducted in the taxable year such service was furnished to the customers.
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Petitioners, regulated public utility companies, reported income on an accrual calendar year basis. Petitioners employed the cycle meter reading method of accounting for tax purposes. Consequently, revenue generated for utility services furnished after the last cycle meter reading date in December was not accrued until after the close of the taxable year. Expenses related to such utility services were deducted in the taxable year such service was furnished to the customers. For financial statement purposes, petitioners accrued so-called unbilled revenue relating to utility services furnished…
1Opinion of the Court
HAMBLEN, Judge:
Respondent determined deficiencies with respect to the Federal income tax liability of petitioners as follows:
Petitioner Year Deficiency
Orange & Rockland Utilities, Inc. 1976 $4,239,516
(O & R)
Rockland Electric Co. (Rockland) 1976 2,813
Orange & Rockland Utilities, Inc., 1977 1,651,500
and Subsidiaries (O & R group)
After concessions,1 the issue presented for decision is whether petitioners may use the “cycle meter reading” method of accounting for Federal income tax purposes where such method does not conform to the method of accounting used by petitioners for financial statement…
2Cases cited14 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Madison Gas and Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
9 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2000
- Hallmark Cards, Inc. v. CommissionerUnited States Tax Court · 1988
- RLC Indus. Co. v. CommissionerUnited States Tax Court · 1992
- Ford Motor Co. v. CommissionerUnited States Tax Court · 1994
- Consumers Power Co. v. CommissionerUnited States Tax Court · 1987
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