Madison Gas & Electric Co. v. Commissioner
United States Tax Court
Held: 1. Since petitioner's computation of cost of coal consumed in generating electric power on the basis of average monthly cost per ton of coal purchased clearly reflected its income because, except on rare occasions, petitioner used each month the same amount of coal purchased that month, respondent abused his discretion in changing petitioner's method of computing cost of coal consumed to in effect an inventory method on a first-in, first-out basis. 2. Petitioner's…
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Held: 1. Since petitioner's computation of cost of coal consumed in generating electric power on the basis of average monthly cost per ton of coal purchased clearly reflected its income because, except on rare occasions, petitioner used each month the same amount of coal purchased that month, respondent abused his discretion in changing petitioner's method of computing cost of coal consumed to in effect an inventory method on a first-in, first-out basis. 2. Petitioner's agreement with two other electric utility companies for construction and operation of a nuclear power plant created a…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax for the taxable years 1969 and 1970 in the amounts of $36,887.50 and $65,258.31, respectively.
The issues for decision are:(1) Whether respondent erred in changing petitioner’s method of accounting for coal consumed at one of its generating plants;(2) Whether the amounts of $33,418.45 and $114,434.27 for the years 1969 and 1970 paid by petitioner as training and related expenses of a new nuclear power plant being constructed by petitioner and two other electric utility companies on a joint participating basis…
2Cases cited47 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
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3Cited by104 opinions
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
- Antonides v. CommissionerUnited States Tax Court · 1988
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Waddell v. CommissionerUnited States Tax Court · 1986
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