FPL Group, Inc. - Page 14




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          and depreciated over the life of the relevant asset”.  INDOPCO,             
          Inc. v. Commissioner, 503 U.S. 79, 83-84 (1992).  This Court has            
          held that the determination of whether an expenditure constitutes           
          a capital expenditure or a currently deductible expense involves            
          the question of the proper time for taking a deduction.  See                
          Pelaez & Sons, Inc. v. Commissioner, 114 T.C. 473, 489 (2000);              
          Southern Pac. Transp. Co. v. Commissioner, 75 T.C. 497, 683                 
          (1980), supplemented by 82 T.C. 122 (1984); Hooker Indus., Inc.             
          v. Commissioner, T.C. Memo. 1982-357; sec. 1.446-1(e)(2)(ii)(a),            
          Income Tax Regs.  An accounting practice involving the timing of            
          when an item is deducted is considered a method of accounting.              
          See GMC & Subs. v. Commissioner, 112 T.C. 270, 296 (1999);                  
          Knight-Ridder Newspapers, Inc. v. United States, 743 F.2d 781,              
          797-798 (11th Cir. 1984).                                                   
               In Southern Pac. Transp. Co. v. Commissioner, supra, we                
          applied section 1.446-1(e)(2)(ii)(b), Income Tax Regs., for                 
          purposes of deciding whether the expenditures in issue were for a           
          “material item”.  Section 1.446-1(e)(2)(ii)(b), Income Tax Regs.,           
          provides that “a correction to require depreciation in lieu of a            
          deduction for the cost of a class of depreciable assets which had           
          been consistently treated as an expense in the year of purchase             
          involves the question of the proper timing of an item, and is to            
          be treated as a change in method of accounting.”  Although the              
          taxpayer in Southern Pac. Transp. Co. v. Commissioner, supra, was           






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