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Introduction

SECTION 1. PURPOSE

Internal Revenue Bulletin 2005-28 · 2026-10-03 edition · updated 2026-10-04 · United States

This revenue procedure sets forth a safe harbor method of accounting for a Utility’s treatment of an Up-front Payment that the Utility receives from a Generator to finance Network Upgrades to the Utility’s Transmission System. This revenue procedure also provides a procedure for a Utility to obtain automatic consent of the Commissioner to change to the safe harbor method of accounting. Finally, this revenue procedure provides audit protection to a Utility that has used the safe harbor method of accounting, provided that certain conditions are satisfied.

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▸Contents — Internal Revenue Bulletin 2005-28

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