FPL Group, Inc. - Page 35




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          of reviewing the effects of petitioner’s recharacterization, such           
          as adjusting for claimed depreciation, would defeat the                     
          accounting goal of promoting uniformity, to say nothing of the              
          complex computations and inconvenience in administering the tax             
          laws.  Petitioner’s attempted recharacterization is precisely the           
          type of change which frustrates the purpose of section 446(e) and           
          renders the consent requirement necessary.                                  
          V.   Conclusion                                                             
               Petitioner consistently used a method of accounting of                 
          following regulatory rules and guidelines for regulatory,                   
          financial, and tax reporting purposes for the expenditures in               
          issue.  Petitioner’s attempt to alter its classification of the             
          expenditures changes the timing of deductions related to those              
          expenditures and thus is a change in the treatment of a material            
          item.  This change in treatment of a material item does not                 
          result from a correction or a change in underlying facts.                   
          Petitioner did not seek respondent’s consent, nor did respondent            
          impliedly consent or waive the right to challenge petitioner’s              
          recharacterization as an impermissible change of accounting                 
          method.  Petitioner’s claimed recharacterization frustrates the             
          purpose of section 446(e).  Accordingly, we hold that                       
          petitioner’s attempted recharacterization of the expenditures in            










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