CITY GAS COMPANY OF FLORIDA v. COMMISSIONER

Docket Nos. 8807-73, 8808-73, 8809-73.

47 T.C.M. 971 (1984)

T.C. Memo. 1984-44

City Gas Company of Florida, et al. v. Commissioner.

United States Tax Court.

Filed January 26, 1984.


Attorney(s) appearing for the Case

David W. Richmond and Charles J. Monahan for the petitioners. David M. Berman for the respondent.


Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

These cases are before this Court on remand from the Court of Appeals for the Eleventh Circuit. The issues for decision are:

1. Whether the petitioner-utility companies realized income as a result of receiving security deposits from their customers;

2. If so, in what year the income must be recognized; and

3. Whether the treatment of the deposits urged by respondent constitutes...

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