- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011