Illinois Power Co. v. Commissioner
United States Tax Court
The construction of the Baldwin Power Station, a multiunit electric generating station commenced in March of 1967. The construction of unit 3 began in 1971 and it was placed in commercial service on June 20, 1975. Sargent & Lundy, an engineering partnership, designed and provided construction management for the project, and Baldwin Associates, a joint venture of construction companies, performed the actual physical construction of unit 3. Petitioner Illinois Power provided…
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The construction of the Baldwin Power Station, a multiunit electric generating station commenced in March of 1967. The construction of unit 3 began in 1971 and it was placed in commercial service on June 20, 1975. Sargent & Lundy, an engineering partnership, designed and provided construction management for the project, and Baldwin Associates, a joint venture of construction companies, performed the actual physical construction of unit 3. Petitioner Illinois Power provided general criteria for unit 3 to its agent, Sargent & Lundy, purchased all major components, approved specifications,…
1Opinion of the Court
Wilbur, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income tax:
TYE Dec. 31— Amount
1975 . $7,090,791.12
1976 . 644,094.74
After concessions, two issues remain for our consideration:(1) Whether unit 3 of petitioner’s Baldwin Power Station was constructed by the petitioner or acquired by the petitioner for purposes of computing the investment tax credit; and(2) Whether amounts designated as "Rider R Income” collected from certain gas utility customers constitute taxable income in the . year of receipt.
Some of the facts have been stipulated and are found…
2Cases cited28 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- James v. United StatesSupreme Court of the United States · 1961
- South Corporation and Seal Fleet, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1982
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3Cited by11 opinions
- Illinois Power Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Continental Illinois Corp. v. CommissionerUnited States Tax Court · 1989
- Indianapolis Power & Light Co. v. CommissionerUnited States Tax Court · 1987
- Iowa Southern Utilities Co. v. United StatesUnited States Court of Claims · 1987
- Carlstedt Associates, Inc. v. CommissionerUnited States Tax Court · 1989
6 more not listed; retrieve them via the Exa API.