MidAmerican Energy Company - Page 13




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            and that to accrue revenue from gas costs for the period                                   
            following the December meter-reading date to December 31                                   
            (unbilled period) results in double counting.  Respondent                                  
            contends that petitioner’s method of accounting fails the                                  
            requirements of section 451(f) and that petitioner must include                            
            in taxable income amounts attributable to utility services, gas                            
            costs and nongas margin, provided during the taxable year,                                 
            including the unbilled period.                                                             
                  Section 446(a) generally provides that taxable income shall                          
            be computed under the method of accounting that the taxpayer                               
            regularly uses to compute income for financial accounting                                  
            purposes.  If such method of accounting does not clearly reflect                           
            income, “the computation of taxable income shall be made under                             
            such method as, in the opinion of the Secretary, does clearly                              
            reflect income.”  Sec. 446(b).                                                             
                  Prior to the passage of section 451(f) in the Tax Reform Act                         
            of 1986, Pub. L. 99-514 sec. 821, 100 Stat. 2372, petitioner                               
            recognized taxable income from utility services based on the                               
            taxable year in which its customers’ utility meters were read                              
            (the cycle meter-reading method).  See Rev. Rul. 72-114, 1972-1                            
            C.B. 124.  Under the cycle meter-reading method, utility services                          
            provided to customers during the unbilled period were not                                  
            recognized as income until the following taxable year.  See id.                            
            Recognizing that the cycle meter-reading method allowed utilities                          






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