IRS PLR: Nuclear Plant Decommissioning Costs Proposed Revised Schedule Approved (IRC §468A)

In three letter rulingss, the IRS ruled that a wholly owned subsidiary’s nuclear plant decommissioning proposed revised schedule of ruling amounts was found to meet the requirements of tax code Section 468A and regulations thereunder, having determined that: (1) Taxpayer has a qualifying interest in the plant and is, therefore, an eligible taxpayer under Treasury Regulations Section 1.468A-1(b)(1), and (2) has calculated its decommissioning costs under Treas. Reg. Section 1.468A-3(d)(3); (3) the schedule was derived from following “reasonable assumptions” contained in an independent study; and (4) the maximum amount of cash payments made (or deemed ...