FPL Group, Inc. v. Commissioner
United States Tax Court
On its consolidated Federal income tax returns for the years in issue, F claimed a credit for Federal taxes on fuels. F now seeks credits in addition to amounts claimed on F's original Federal income tax returns. R argues that the so-called "one claim" rule contained in sec. 6427(i)(1), I.R.C., acts as a bar to F's additional claims for credit under sec. 34, I.R.C.
Read the full summary
On its consolidated Federal income tax returns for the years in issue, F claimed a credit for Federal taxes on fuels. F now seeks credits in addition to amounts claimed on F's original Federal income tax returns. R argues that the so-called "one claim" rule contained in sec. 6427(i)(1), I.R.C., acts as a bar to F's additional claims for credit under sec. 34, I.R.C. HELD: F is not barred by the so-called "one claim" rule of sec. 6427(i)(1), I.R.C., from obtaining additional credits under sec. 34, I.R.C.
1Opinion of the Court
OPINION
RUWE, Judge:
This matter is before the Court on respondent’s motion for partial summary judgment filed pursuant to Rule 121.1 The sole issue presented is whether petitioner is barred by the so-called “one claim” rule of section 6427(i)(l) from obtaining a credit under section 34 for amounts of Federal excise taxes paid on fuels.
Background
FPL Group, Inc., is a corporation organized and existing under the laws of the State of Florida with its principal office located in Juno Beach, Florida. FPL Group, Inc. & Subsidiaries (petitioner) filed consolidated Federal income tax returns for the…
2Cases cited7 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
- Shiosaki v. CommissionerUnited States Tax Court · 1974
- Bond v. CommissionerUnited States Tax Court · 1993
2 more not listed; retrieve them via the Exa API.
3Cited by130 opinions
- Rauenhorst v. Comm'rUnited States Tax Court · 2002
- Cooper v. Comm'rUnited States Tax Court · 2011
- Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2003
- Lindberg v. Comm'rUnited States Tax Court · 2010
- Guardian Industries Corp. v. CommissionerUnited States Tax Court · 2014
125 more not listed; retrieve them via the Exa API.