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Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for 1992, and Rule references are
to the Tax Court Rules of Practice and Procedure. All dollar
amounts are rounded.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulated facts and exhibits are incorporated herein by this
reference.
I. FPL
FPL, the stock of which is publicly traded, is a holding
company and the parent of various wholly owned subsidiaries
including Florida Power and Light Co. (Florida Power), the largest
electric public utility in the State of Florida, and FPL Capital
Group (FPL Capital). FPL filed consolidated returns with its
various subsidiaries during the period in question.
A. FPL Officers
Paul Evanson assumed the position of chief financial officer
of FPL on December 7, 1992. Prior to joining FPL, Mr. Evanson’s
professional experience included 6 years as a tax specialist at
Arthur Andersen, a large firm of certified public accountants, and
5 years as president and chief operating officer of Lynch Corp.
Prior to his employment at Arthur Andersen, Mr. Evanson was awarded
a juris doctor degree from Columbia University School of Law and an
LL.M. in taxation degree from New York University.
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