116 T.C. No. 7
UNITED STATES TAX COURT
FPL GROUP, INC. AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5271-96. Filed February 1, 2001.
On its consolidated Federal income tax returns for
the years in issue, F claimed a credit for Federal
taxes on fuels. F now seeks credits in addition to
amounts claimed on F’s original Federal income tax
returns. R argues that the so-called “one claim” rule
contained in sec. 6427(i)(1), I.R.C., acts as a bar to
F’s additional claims for credit under sec. 34, I.R.C.
Held: F is not barred by the so-called “one
claim” rule of sec. 6427(i)(1), I.R.C., from obtaining
additional credits under sec. 34, I.R.C.
Robert Thomas Carney, for petitioner.
James F. Kearney, for respondent.
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