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Co. v. Commissioner, 93 T.C. at 510-511 (quoting Black’s Law
Dictionary 1050 (5th ed. 1979)). Petitioner does not contend
that it erred in transferring the amount or characterization of
expenditures reported by Florida Power for regulatory purposes to
petitioner’s tax return. Rather, petitioner relies on Northern
States Power Co. v. United States, supra, in arguing that it
erroneously capitalized the expenditures at issue and that the
attempted recharacterization should be treated as a posting
error. Petitioner’s reliance on Northern States Power Co. v.
United States, supra is misplaced. In Northern States Power Co.
v. United States, supra, the taxpayer’s tax department was
unaware that certain amounts were improperly recorded in its
accounts. Because the taxpayer lacked knowledge of the error, it
mistakenly capitalized the amounts instead of currently deducting
them. See id. at 884. When it discovered the mistake, the
taxpayer promptly filed refund claims in an effort to treat the
amounts in the same manner that it had consistently treated
similar items. See id. The court held that the taxpayer’s
mistake was more “akin to a posting error” than a change in
method of accounting. Id.
In the instant case, petitioner consciously chose to use the
same characterization of expenditures for tax reporting purposes
that Florida Power used for regulatory accounting and financial
reporting purposes. Petitioner gave no notice on its returns
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