- 3 - petitioner. Petitioner filed consolidated returns with Florida Power during the years in issue. On December 28, 1995, respondent issued a notice of deficiency for the taxable years 1988 through 1992. In its First Amended Petition, filed May 13, 1996, petitioner argued for the first time that respondent erred in failing to allow a deduction for certain repair expenses related to Florida Power when determining the deficiency amounts in the notice of deficiency. Petitioner claimed that it had improperly characterized the following expenditures related to Florida Power as capital expenditures and that it should have deducted them as repair expenses: Year Amount 1988 $35,324,412 1989 52,115,791 1990 54,746,820 1991 56,823,897 1992 11,914,614 Total 210,925,534 Petitioner did not file a Form 3115, Application for Change in Accounting Method, with respondent to request a change in accounting method for the expenditures at issue. Respondent did not raise the change in accounting method issue prior to the filing of his motion for partial summary judgment. Florida Power owns and operates fossil and nuclear electric generating plants in Florida and also owns interests in coal- fired electric generating plants in Georgia and Florida, whichPage: 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