T.C. Memo. 1999-77 UNITED STATES TAX COURT LYKES ENERGY, INC. AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 7685-96; 4979-97. Filed March 11, 1999. S, a gas utility company, collected funds from its customers which were earmarked for legislatively mandated energy conservation programs. The State required S to account separately for the funds and monitored program expenditures. S could not retain the unexpended amounts and was charged interest on the funds that exceeded expenditures. The largest expenditure was subsidies paid to purchasers of gas appliances from S. S' sales, customer base, and rate base increased as a result of the programs. Held: S' gross income includes the funds. Held, further, S must capitalize the expenditures, less the amount paid as subsidies, which is currently deductible. Nathan B. Simpson and Matthew J. Foster, for petitioners. William A. Goss and Benjamin A. DeLuna, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011