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Practice and Procedure. Dollar amounts are rounded to the
nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits submitted therewith are
incorporated herein by this reference. Lykes is the parent
corporation of an affiliated group of corporations that files
consolidated Federal income tax returns based on a fiscal year
ending on September 30. Lykes was headquartered in Tampa,
Florida, when the petitions were filed.
People's distributes natural gas in Florida. It is a
utility subject to regulation by the Florida Public Service
Commission (PSC). Pursuant to the Florida Energy Efficiency and
Conservation Act (FEECA), the PSC required that People's design
and administer the FEECA programs. People's administers these
programs subject to the PSC's supervision. The FEECA programs
are generally designed to reduce consumption of high cost
petroleum and to lower electrical energy consumption.
For its 1988 through 1991 taxable years, People's included
receipts from the FEECA programs (FEECA receipts) in its gross
income, and it deducted its expenditures under the programs
(FEECA expenditures). Starting with its 1992 taxable year,
People's excluded FEECA receipts from its gross income and did
not deduct any FEECA expenditures.
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Last modified: May 25, 2011