PER CURIAM:
Petitioner-Appellant, Florida Progress Corporation, appeals the Tax Court's decision denying Florida Progress's request to treat certain bill credits and checks issued to its customers as "refunds" entitled to preferential tax treatment under 26 U.S.C. § 1341(a). The Tax Court ruled that because the putative refunds were really disguised rate reductions, they were not eligible for treatment under that provision.
I.
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