Legal Opinion

Madison Gas & Electric Co. v. Commissioner

United States Tax Court

Decided June 21, 1979No. Docket No. 8669-74Published

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

Madison Gas and Electric Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Madison Gas & Electric Co. v. Commissioner

Docket No. 8669-74

United States Tax Court

72 T.C. 521; 1979 U.S. Tax Ct. LEXIS 98;

June 21, 1979, Filed

Decision will be entered under Rule 155.

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…

2Cases cited49 opinions

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. Lucas v. American Code Co.Supreme Court of the United States · 1930
  4. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
  5. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979

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