Actions Relating to Decisions of the Tax Court
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Internal Revenue Bulletin 2003-17 · 2026-10-03 edition · updated 2026-10-04 · United States
plete dominion over the overrecoveries and was not required to recognize them in income.
The Service has concluded, based on the decisions in Houston Industries, Florida Progress, and Cinergy that taxpayers may exclude fuel cost and energy conservation cost overrecoveries from gross income in cases involving facts substantially similar to the above cases.
DRAFTING INFORMATION
The principal author of this revenue ruling is Jeffrey S. Marshall of the Office of Associate Chief Counsel (Income Tax and Accounting). For further information regarding this revenue ruling, contact Mr. Marshall at (202) 622–4960 (not a tollfree call).
Section 355.—Distribution of Stock and Securities of a Controlled Corporation
26 CFR 1.355–3: Active conduct of a trade or business.
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