- 2 - to Rule 121.1 Petitioner seeks a determination that its method of accounting, for purposes of determining repair versus capital expenses for the taxable years 1988 to 1992, is what petitioner characterizes as “the method required by Section 1.162-4 of the Regulations”. In its first amended petition, petitioner claimed that under this “method of accounting” it is entitled to additional deductions for repair expenses in the following amounts: Year Amount 1988 $35,324,412 1989 52,115,791 1990 54,746,820 1990 56,823,897 1992 11,914,614 Total 210,925,534 The amounts in issue are expenditures made by petitioner’s wholly owned subsidiary, Florida Power & Light Co. (Florida Power), an electric utility. Petitioner filed consolidated returns with Florida Power during the years in issue. As a utility, Florida Power was subject to the regulatory rules of the Federal Energy Regulatory Commission (FERC) and the Florida Public Service Commission (FPSC). 1 Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011