Public Service Co. v. Commissioner
United States Tax Court
Petitioner, a regulated electric utility, reported its income on an accrual calendar year basis and utilized the meter reading and billing cycle of accounting for sales of electricity. Sales of electricity after the last meter reading in December were not billed to customers until after the close of the calendar year. On its income tax return for that year, it deducted the expenses but did not report the income attributable to such sales.
Read the full summary
Petitioner, a regulated electric utility, reported its income on an accrual calendar year basis and utilized the meter reading and billing cycle of accounting for sales of electricity. Sales of electricity after the last meter reading in December were not billed to customers until after the close of the calendar year. On its income tax return for that year, it deducted the expenses but did not report the income attributable to such sales. It did, however, reflect such income on its books of account and financial statements. Because of the foregoing disparity, respondent determined that income…
1Opinion of the Court
OPINION
Tannenwald, Chief Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
Year Deficiency
1968 . $96,097
1971 . 71,097
1972 . 726,906
1975 . 1,183,857
The sole issue presented is whether petitioner may use a method of accounting for filing its tax returns which causes it to defer until 1976 recognition of income attributable to certain sales of electricity occurring in December of 1975.1
This case was submitted fully stipulated pursuant to Rule 122.2 The stipulation of facts is incorporated by this reference.
Petitioner is a New Hampshire corporation engaged…
2Cases cited30 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
- Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930
25 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
- Thomas v. CommissionerUnited States Tax Court · 1989
- Consumers Power Co. v. CommissionerUnited States Tax Court · 1987
- Orange & Rockland Utilities, Inc. v. CommissionerUnited States Tax Court · 1986
14 more not listed; retrieve them via the Exa API.