FPL Group, Inc. - Page 2




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               accounting under sec. 446(e), I.R.C.; therefore, P is                  
               not entitled to the claimed expense deductions.                        


               Robert Thomas Carney, for petitioner.                                  
               Gary F. Walker, Sergio Garcia-Pages, and Robert W. Dillard,            
          for respondent.                                                             


                                       OPINION                                        

               RUWE, Judge:  This matter is before the Court on                       
          respondent’s motion for partial summary judgment filed pursuant             
          to Rule 121.1  The sole issue presented is whether petitioner’s             
          attempt to recharacterize as repair expenses, expenditures which            
          it had characterized on its tax returns as capital expenditures             
          for the taxable years 1988 to 1992, is an impermissible change in           
          accounting method under section 446(e).                                     
                                     Background                                       
               FPL Group, Inc. (petitioner) is a corporation organized and            
          existing under the laws of the State of Florida with its                    
          principal office located in Juno Beach, Florida.  Florida Power &           
          Light Co. (Florida Power) is a wholly owned subsidiary of                   




               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  





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