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BASIN ELECTRIC POWER COOPERATIVE v. COMMISSIONER

Docket No. 14792-02.

87 T.C.M. 1266 (2004)

T.C. Memo. 2004-109

Basin Electric Power Cooperative v. Commissioner.

United States Tax Court.

Filed May 3, 2004.

Attorney(s) appearing for the Case

Sue Ann Nelson and Robert J. Stuart, for petitioner.

Reid M. Huey, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax (tax):

  Taxable Year  Deficiency
      1992        $123,999
      1993         300,475
      1995         306,346
      1996       1,228,868

The issues remaining for decision are:

(1) Should the Court sustain respondent's determination that the expenditures at issue must be capitalized...

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