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COMMISSIONER v. INDIANAPOLIS POWER & LIGHT CO.

No. 88-1319.

493 U.S. 203 (1990)

COMMISSIONER OF INTERNAL REVENUE v. INDIANAPOLIS POWER & LIGHT CO.

Supreme Court of United States.

Decided January 9, 1990

Attorney(s) appearing for the Case

Deputy Solicitor General Wallace argued the cause for petitioner. With him on the briefs were Solicitor General Starr, Acting Assistant Attorney General Knapp, Alan I. Horowitz, Jonathan S. Cohen, and William A. Whitledge.

Larry J. Stroble argued the cause for respondent. With him on the brief was Stanley C. Fickle.*

JUSTICE BLACKMUN delivered the opinion of the Court.

Respondent Indianapolis Power & Light Company (IPL) requires certain customers to make deposits with it to assure payment of future bills for electric service. Petitioner Commissioner of Internal Revenue contends that these deposits are advance payments for electricity and therefore constitute taxable income to IPL upon receipt. IPL contends otherwise.

I

IPL is a regulated Indiana corporation...

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