FPL Group, Inc. - Page 27




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          characterizations that Florida Power used for regulatory and                
          financial reporting purposes.  Accordingly, we hold that the                
          audit adjustments by respondent do not establish the method of              
          accounting that petitioner is claiming.                                     
               Petitioner’s treatment of the expenditures in issue for tax            
          purposes was consistent with the treatment of those expenditures            
          by Florida Power for regulatory accounting and financial                    
          reporting purposes.  The Schedules M-1 adjustments are, at best,            
          relatively minor deviations from petitioner’s method of                     
          accounting.  The Schedules M-1 adjustments for the PRA and the              
          storm reserve, and the audit adjustments by respondent, do not              
          change the fact that petitioner is retroactively attempting to              
          recharacterize expenditures that it regularly and consistently              
          capitalized for regulatory, financial, and tax reporting                    
          purposes.  See Potter v. Commissioner, 44 T.C. 159, 167 (1965)              
          (methods of accounting must be regular and consistent).                     
          II. Correction                                                              
               A change in method of accounting does not occur when a                 
          taxpayer seeks to correct mathematical or posting errors, errors            
          in the computation of tax liability, a change in treatment                  
          arising from a change in underlying facts, or any other                     
          “adjustment of any item of income or deduction which does not               
          involve the proper time for the inclusion of the item of income             
          or the taking of a deduction.”  Northern States Power Co. v.                






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