- 13 - 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 utilitiesPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011