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Petitioner consistently applied the characterizations used
by Florida Power for regulatory purposes when reporting for tax
purposes. Petitioner made no references in its tax returns that
would notify respondent that the amount of claimed repair
expenses was a “reasonable approximation” and represented the
method of accounting that petitioner is claiming. For the year
1992, petitioner filed two amended returns. In its first amended
return, filed in September of 1993, petitioner claimed an
adjustment for storm expenses and an additional repair expense
for cable injection costs. In its second amended return, filed
in December of 1993, petitioner claimed additional repair
expenses for the same type of expenditures as those currently in
issue and an adjustment for storm expenses. After reviewing the
original and amended returns and meeting with petitioner,
respondent allowed some of the claimed expenditures to be
deducted as repair expenses and accepted the adjustment for storm
expenses. Petitioner has not alleged, nor is there any
indication, that respondent acquiesced in a method of accounting
which would allow petitioner to “approximate” the amount of
repair expenses and then file amended returns when, and if, it
realized it might have deducted a larger amount. The fact that
petitioner amended its 1992 tax return for additional expense
claims does not change the fact that, in preparing its original
tax return, petitioner consistently used the same
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