IRC Authority Graph

§821

25 cases·4 followed·1 distinguished·1 criticized·2 limited·17 cited—16% support

Statute Text — 26 U.S.C. §821

Statute text not available for this section.

25 Citing Cases

Florida Progress Corporation and Subsidiaries, Petitioner 114 T.C. No. 36 · 2000

ility filing consolidated Federal income tax returns with P, engaged in the retail and wholesale distribution of electricity and related services. Federal income tax rates were reduced in 1986 pursuant to the Tax Reform Act of 1986, Pub. L. 99-514, sec. 821, 100 Stat. 2372, creating an excess in deferred Federal income tax collected from customers of U. U was required to adjust utility rates in 1987 and 1988 to compensate for this overcollection. U was allowed to collect funds equal to its proje

MidAmerican Energy Company, Petitioner 114 T.C. No. 35 · 2000

2372, creating an excess in deferred Federal income tax. P was required to adjust utility rates from 1987 through 1990 to compensate for this overcollection. Held: P’s method of accounting for utility services from the unbilled period violates sec. 451(f) and must be disallowed. Held, further, P must adjust the sec. 481 adjustme

MidAmerican Energy Company, Petitioner 114 T.C. No. 35 · 2000

2372, creating an excess in deferred Federal income tax. P was required to adjust utility rates from 1987 through 1990 to compensate for this overcollection. Held: P’s method of accounting for utility services from the unbilled period violates sec. 451(f) and must be disallowed. Held, further, P must adjust the sec. 481 adjustme

Eldon R. & Susan M. Kenseth, Petitioner 114 T.C. No. 26 · 2000

821.01 (1999) (Uniform Certification of Questions of Law Rule). - 67 - recently adopted by the Court of Appeals for the Sixth Circuit in Estate of Clarks v. United States, supra. The primary point made by Judges Rives and Brown was that in a practical sense the taxpayer never had control over the portion of the recovery that was retained by h

Coppola v. Beeson (In Re Coppola) 419 F.3d 323 · Cir.
Meridian Mutual Insurance v. Commissioner 44 T.C. 375 · 1965
Consumers Power Co. v. Commissioner 89 T.C. 710 · 1987
Philadelphia Manufacturers Mutual Insurance v. Commissioner 33 T.C. 490 · 1959
Modern Life & Accident Insurance v. Commissioner 49 T.C. 670 · 1968
Union Mutual Insurance v. Commissioner 46 T.C. 842 · 1966
Estate of Moyer v. Commissioner 32 T.C. 515 · 1959
Estate of Derby v. Commissioner 20 T.C. 164 · 1953
Home Mutual Insurance v. Commissioner 70 T.C. 944 · 1978
Gajewski v. Commissioner 67 T.C. 181 · 1976
Allied Utilities Corp. v. Commissioner 64 T.C. 1024 · 1975
Millers National Insurance v. Commissioner 54 T.C. 457 · 1970
Schuster v. Commissioner 32 T.C. 998 · 1959
Englert v. Commissioner 32 T.C. 1008 · 1959
Estate of Weisberger v. Commissioner 29 T.C. 217 · 1957
Estate of Werbelovsky v. Commissioner 9 T.C. 689 · 1947
United States v. Isac Schwarzbaum 114 F.4th 1319 · Cir.
United States v. Isac Schwarzbaum 127 F.4th 259 · Cir.
Arthur Bedrosian v. United States 912 F.3d 144 · Cir.
United States v. Jane Boyd 991 F.3d 1077 · Cir.
United States v. Bittner · Cir.