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FPL GROUP, INC. v. COMMISSIONER

Docket No. 5271-96.

115 T.C. 554 (2000)

FPL GROUP, INC. & SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 13, 2000.

Attorney(s) appearing for the Case

Robert Thomas Carney, for petitioner.

Gary F. Walker, Sergio Garcia-Pages, and Robert W. Dillard, for respondent.

OPINION

RUWE, Judge:

This matter is before the Court on respondent's motion for partial summary judgment filed pursuant to Rule 121.1 The sole issue presented is whether petitioner's attempt to recharacterize as repair expenses, expenditures which it had characterized on its tax returns as capital expenditures for the taxable years 1988 to 1992 is an impermissible change in accounting...

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