Legal Opinion

Northern States Power Company, Cross-Appellant/appellee v. United States of America, Appellant/cross-Appellee

Court of Appeals for the Eighth Circuit

Decided August 12, 1998No. 97-2914, 97-2915PublishedCited by 13 opinions

1Opinion of the Court

GOLDBERG, Judge.

This tax refund dispute raises two independent issues. First, when did the taxpayer, Northern States Power Co. (“NSP”), place two shipments of nuclear fuel assemblies into service, and thereby become eligible to claim a depreciation deduction and an investment tax credit? And second, when NSP filed refund claims currently deducting certain losses that it had previously capitalized, did NSP change its method of accounting? NSP filed this action to recover a refund for taxes levied and collected by the Internal Revenue Service (“IRS”) for the years 1985 and 1986. With respect to…

2Cases cited17 opinions

  1. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
  2. United States v. Thomas W. TierneyCourt of Appeals for the Eighth Circuit · 1991
  3. Piggly Wiggly Southern, Inc., Southern Graphic Art and Georgia Sales Company v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
  4. Piggly Wiggly Southern, Inc. v. CommissionerUnited States Tax Court · 1985
  5. Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948

12 more not listed; retrieve them via the Exa API.

3Cited by13 opinions

  1. FPL Group, Inc. v. CommissionerUnited States Tax Court · 2000
  2. Capital One Fin. Corp. v. Comm'rUnited States Tax Court · 2008
  3. Exxon Mobil Corp. v. CommissionerUnited States Tax Court · 2000
  4. H.E. Butt Grocery Co. v. United StatesDistrict Court, W.D. Texas · 2000
  5. Cargill, Inc. v. United StatesDistrict Court, D. Minnesota · 2000

8 more not listed; retrieve them via the Exa API.

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