Midamerican Energy Company v. Commissioner of Internal Revenue

MORRIS SHEPPARD ARNOLD, Circuit Judge.

MidAmerican Energy Company, a public utility and retail distributor of electricity and natural gas, sued the Commissioner of Internal Revenue in 1997, largely as a result of changes to the Internal Revenue Code. MidAmerican claimed in that suit that it was being double-taxed at the end of the year because the Commissioner incorrectly rejected its method of accounting, and that it was entitled to a deduction after state regulators forced it to disgorge “excessive” profits. The Tax Court rejected both claims. See MidAmerican Energy v. Commissioner, 114 T.C.…