114 T.C. No. 35 UNITED STATES TAX COURT MIDAMERICAN ENERGY COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 22728-97, 22729-97, Filed June 30, 2000. 22730-97, 22731-97. P is a public utility engaged in the retail distribution of natural gas, electricity, and related services. In 1987, in response to the enactment of sec. 451(f), I.R.C., P modified its method of accounting for tax purposes to coincide with its financial and regulatory accounting method and made a sec. 481 adjustment. Federal income tax rates were reduced in 1986 pursuant to the Tax Reform Act of 1986, Pub. L. 99-514, sec. 821, 100 Stat. 2372, creating an excess in deferred Federal income tax. P was required to adjust utility rates from 1987 through 1990 to compensate for this overcollection. Held: P’s method of accounting for utility services from the unbilled period violates sec. 451(f) and must be disallowed. Held, further, P must adjust the sec. 481 adjustment it made in 1986 to include revenue attributable to gas costs from the unbilledPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011