MidAmerican Energy Company - Page 15




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            the calendar year and makes an accrual for nongas margin from the                          
            unbilled period.  According to section 451(f), a utility must                              
            include in taxable income the revenue attributable to utility                              
            services provided during the taxable year.  See S. Rept. 99-313,                           
            supra, 1986-3 C.B. (Vol. 3) at 120-121.  Utility services are                              
            “provided” when such services are made available to, and used by,                          
            the customer.  Id.  “The taxable year in which services are                                
            treated as provided to customers shall not, in any manner, be                              
            determined by reference to (i) the period in which the customers’                          
            meters are read, or (ii) the period in which the taxpayer bills                            
            (or may bill) the customers for such service.”  Sec.                                       
            451(f)(2)(B).  On average, petitioner’s method of accounting                               
            includes in taxable income utility services provided from                                  
            December 15 of the prior year to December 15 of the current year.                          
            With respect to the unbilled period, we see no difference in                               
            petitioner’s treatment of revenue from gas costs under its                                 
            current method of accounting and the cycle meter-reading method                            
            of accounting that section 451(f) was intended to eliminate.                               
            While it is true that a full year’s worth of income from utility                           
            service is included in determining taxable income, the included                            
            year is not the same as the year intended by section 451(f).                               
            Congress there specified that the income attributable to utility                           
            services must be reported for the same year in which the services                          
            were provided.                                                                             






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