FPL Group, Inc. - Page 24




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          characterization of expenditures for regulatory accounting and              
          financial reporting purposes.  The PRA simply allowed petitioner            
          to characterize a set percentage of expenditures as repair                  
          expenses for tax purposes.                                                  
               Petitioner is now trying to recharacterize as repairs, items           
          that it characterized as capital expenditures for tax purposes.             
          Petitioner cannot recharacterize amounts capitalized under the              
          PRA because to do so would violate the percentage limitation.               
          Petitioner does not identify any adjustments in the PRA or claim            
          that it made any error in the original computation under the PRA.           
          The expenditures that petitioner is trying to recharacterize are            
          those that petitioner consistently capitalized for regulatory,              
          financial, and tax reporting purposes.  This attempted                      
          recharacterization conflicts with petitioner’s practice of having           
          tax accounting follow regulatory and financial accounting.                  
               B.   Storm Reserve                                                     
               On its original 1992 tax return, petitioner made a Schedule            
          M-1 adjustment of $6 million for a storm reserve related to                 
          Florida Power.  The storm reserve related to an extraordinary               
          item; namely, to offset damages caused by Hurricane Andrew.  This           
          was not a recurring item which petitioner accounted for every               
          year, as evidenced by the absence of any Schedule M-1 adjustment            
          for a storm reserve for any of the other years in issue.                    
          Additionally, petitioner has not claimed that it is seeking to              






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Last modified: May 25, 2011