Southwestern Energy Co. v. Commissioner
United States Tax Court
1. A public utility gas company was authorized by the Public Service Commission to use a "cost of gas adjustment" (CGA) to compute the tariff rates charged to its customers. The purpose of the CGA was to allow the utility to recoup the cost of the gas purchased by it without having to petition the commission for a change in tariff rate each time the cost of gas changed.
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1. A public utility gas company was authorized by the Public Service Commission to use a "cost of gas adjustment" (CGA) to compute the tariff rates charged to its customers. The purpose of the CGA was to allow the utility to recoup the cost of the gas purchased by it without having to petition the commission for a change in tariff rate each time the cost of gas changed. However, since there was a lapse of time between the increase or decrease of the price of gas purchased by the utility and the implementation of the new tariff rate computed pursuant to the CGA, there were underrecoveries or…
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined income tax deficiencies against petitioner for 1985 and 1986 in the amounts of $306,283.10 and $205,922.68, respectively. Petitioner is a group of consolidated corporations consisting of a parent, Southwestern Energy Co. (SW Energy), and subsidiaries which had filed consolidated returns on the accrual basis for those years. Petitioner’s principal place of business when the petition herein was filed was in Fayetteville, Arkansas. The dispute before us relates solely to the parent corporation and to one of the subsidiaries, Arkansas Western Gas Co.…
2Cases cited8 opinions
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- National Can Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1982
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