20141010IRS Accounting Method Change.pdf

<lHm*
An loAcoRP company
n f r- [] tt/ l-: I'tiii-L'rr v *' '"
?$l\ 0[T -9 Pl{t5LISA D. NORDSTROM
Lead Counsel
October 9,2014
Ms. Jean D. Jewell
Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, lD 83720-0074
ldaho Power Company
lnternal Revenue Service Form 3115, Application for Change in Accounting Method
Dear Ms. Jewell:
On September 12,2014,IDACORP, lnc., on behalf of its subsidiary ldaho Power Company
("ldaho Powe/'), filed Form3115, Application for Change in Accounting Method, with the Internal
Revenue Service ("!RS') along with its federal income tax return lor 2013. Pursuant to lRS Rev.
Proc. 2011-14, as modified by Rev. Proc.2012-20, ldaho Power is providing a copy of Form 3115 to
the ldaho Public Utilities Commission ("|PUC") within 30 days of its submittalto the lRS.
The purpose of ldaho Power's Form 3115 was to notify the IRS of a late general asset
account election. Specifically, this Form 3115 is related to all lineartransmission and distribution
assets placed in service after December 31, 1986, and prior to January 1, 2012.
The filing of this election has no impact to the financial statements of IDACORP, Inc. or
ldaho Power. The submission is protective in nature and is unrelated to any change in accounting
for Generally Accepted Accounting Principles purposes. Similarly, there are no ratemaking
implications as a result of the change. Accordingly, as this filing is for informational purposes only,
no action is required of the IPUC nor is action being requested by ldaho Power.
Please find ldaho Power's Form 3115 attached. Thank you for your attention to this matter.
lf you have any questions, please contact Courtney Waites, Senior Regulatory Analyst, at (208)
388-5612.
Very truly yours,
a<r-o ll(^u,*",-
"Lisa D. NordstromL
LDN/KKI
Enclosures
cc dencl:RA Files
Legal Files
Gene Marchioro
Randy Lobb
Terri Carlock
trtrtr
tltr
."," 31 15
Rev DeccmDer 20{)9)Application for Change in Accounting Method OMB No. 1545-01s2
i.,,Bn{lra ol $s Lrssu,,
lnicr.rl Re.h'ri, qir\ri..
Name of filer (name of parent corporaliff i{ a consolidatsd grilp) (soe instructions)
IDACORP, INC,Principal business aclivity code rumbtr (see instructions)
zxlao
Number, slreel, and rom or suite rc, lf a P O- bor. see the inslnrtions LF,.e.ese.0${-qo-f.Im.............lneg].9 .....
P.O. BOX 70
City o. tom, state, and ZIP code Name of contact person (see imtructions)
KILINSKIS
Nama of appllcan(s) (jf differont lhan filer) and idenlification numbe(s) (see insfuctions)persons ielephone numbor
COMPANY (ElN:82-01
lftheapplicantisamembefofaconsolidatedgroup,checkthisbox...>
lf Form 2848, Power of Attomey and Declaration of Representative, is attached (see instuctions for when Form 2848 is
the box to lndicate the type the approprlate box to indicate the typo
change b€ing requcsted.lndividual llCooperative (Sec. 1381)
Corporalion neartnersnip
Controlledforeigncorporation nscorporation
(sec. 957) [lnsurance co (sec. 816(a))
10/50 corporation (Sec. 904(dX2)(E11 [-l lnsurance co. (Sec. 831 )
Oualified personal service f-lOtner lspecify) > . ,. .corporation (Sec. 448(dX2))
Exempt organization. EnterCode section >
Caution. fo be eligible for opprovol al the rcquested change in method ol occounting, the toxpayer must provide oll informotion thot is relevant to the taxpoyer
or to the taxpayer's requested change i^ method of occounting. fhis includes oll informotion requested an this Form 3L15 (including its lnstructions), os
well os any other informotion thot is not specificolly requested.
The taxpaygr must attach atl applicable Euppl€montal 3tatemenb roquested throughout thl3 form.
Enter the applicable designated automatic accounting method change number for the r6quested automalic change, Enier
on{y one designated automatic accounting method change number, oxcept as provided for in guidance published by lhe
lRS. lf the r€quested change has no designatod automatic accounting method change number, check ''Other," and provide
both a description of the change and citation of the IRS guidance providing th6 automatic change. See instructions.
> (a) Change No. 180 (b) Other fl Descripuon >
2 Do any of the scope limitations described in section 4.02 of Rev. Proc. 200&52 cause automatic consent to be
unavailable for the applicanfs requested change? lf "Yes," attach an explanation.SEE.AT.TACHMENT
l{ote: Complele Paft ll below and then Part lV, and also Schedules A E of this form
Did or will the applicant cease to engage in the lrade or business to which the requested change relates, or
terminate its existence, in the tax year of change (see instructions)?
lf "Yes," the applicant is not eligible to make the change under automatic change request prccedures.
4a Does the applicant (or any present or former consolidated group in which the applicant was a member during the
applicable tax year(s)) have any Federal income tax retum(s) under examination (see instructions)?
lf "No,' go to line 5.
b ls the method of accounting the applicant is requesting to change an issue (with respect to either the applicant or
any present or former consolidated group in which the applicant was a member during the applicable tax years(s))
either (i) under consideration or
fsee instrucfions)
Under penalties of perjury, I declar€ thal I havs examined this application, ircluding accompanying schedules and siatements, and to lhe best of my knowledgo and belief,
information of which pr6par6i has any knowledg€
Preparer (other than filer/applicant)
Slgnatwo and Signatre of lndlvidusl preparing the applicaion and d8te
ERIC PEEL. PARTNER
tlame and title (print or typs)Name o, individual preparlng the applicaiion (prhi or type)
OELOITTE TAX LLP
Name o, firm preparlng tho appllcatlon
ldentlfi cation number (Soe lnltruc.tion!)
85{505802
of accounting mcthod
(see instructions)
lil Depreciation or Amortization
fiiinanciaf Products and/or Financial Activities o,
Financial lBtitutions
J-lo,ther(specify) >
STEVEN R. KEEN. VP AND TREASURER
For Prlvacy Act and Papenrork Reduction Act Notlco, s€s the instruction3.Cat No 19280E rorm 3115 (Rev 12-2009)
Form 31 15 (Rev 12.2009)IDACORP. INC Page 2
IIJ lnformation For All Requests (continued)
ls the method of accounting the applicant is requesting to change an issue pending (with respect to either th6
applicant or any present or former consolidated group in which the applicant was a member during the applicable
tax yea(s)) for any tax year under examination (see instructions)?
ls the request to change the method of accounting being filed under the procedures requiring that he operating
division director consent to the filing of the request (see instructions)? . .
lf 'Yes," attach the consent statement from the director.
ls the request to change the method of accounting being filed under the 90-day or 120-day windor period?
Yes
X
x
x
lf 'Yes," check the box for the applicable window period and attach the required statement (see instructions).
lSO Oay I tzo Oay: Date examinalion ended > N/A
f lf you answered "Yes" to line 4a, enter the name and telephone number of the examining agent and the tax
year(s) under examination.
Name > Sherrie Shults Telephone number ) 208-387-2829, x286 Tax yea(s) ) 2ot2 clp prgm
g Has a copy of this Form 3115 been provided to the examining agent identified on line 4f2
5a Does the applicant (or any present or former consolidated group in which the applicant was a member during the
applicable tax yea(s)) have any Federal income tax return(s) before Appeals andlor a Federal court?.
lf "Yes," enter the name of the (check the box) tr Appeals officer and/or f-l counsel for the government,
telephone number, and the tax years(s) before Appeals andlot a Federal court.
Name > NrA Telephone number > tvA Tax yea(s) > l.l/A
b Has a copy of this Form 31'15 been provided to the Appeals officer and/or counsel for the government identified
on line 5a?.
c ls the method of accounting the applicant is requesting to change an issue under consideration by Appeals and/or
a Federal court (for either the applicant or any pres€nt or former consolidated group in which the applicant was a
member for the tax yea(s) the applicant was a member) (see inshuctions)? .
lf 'Yes," attach an explanation. t{/A
6 lf the applicant answered "Yes" to line 4a and/or 5a with respect to any present or former consolidated group,
attach a statement that provides each parent corporation's (a) name, (b) identification number, (c) address,
and (d) tax yea(s) during which the applicant was a member that is under examination, before an Appeals office,
and/or before a Federal court-SEE AT'TACHMENT
lf, forlederal income tax purposes, the applicant is either an entity (including a limited liability company) treated as
a partnership or an S corporation, is it requesting a change from a method of accounting that is an issue under
consideration in an examination, before Appeals, or before a Federal court, with respect to a Federal incrme tax
retum of a partner, member, or shareholder of that entity?
lf "Yes," the applicant is not eligible to make the change. N/A
Does the applicable revenue procedure (advance consent or automatic consent) state that lhe applicant does not
receive audit protection for the requested change (see instructions)?
lf "Yes," attach an explanation. N/A
Has the applicant, its predecessor, or a related party requested or made (under either an automatic change
procedure or a procedure requiring advance consent) a change in method of accounting within the past 5 years
(including the year of the requested change)?
lf"Yes,"foreach trade or business, attach a description ofeach requested change in method ofaccounting
(including the tax year of change) and state whether the applicant received consent.SEE ATTACHMENT
lf any application was withdrawn, not perfected, or denied, or if a Consent Agreement granting a change was not
signed and returned to the lRS, or the change was not made or not made in the requested year of change, attach
an explanation.
Does the applicant, its predecessor, or a related party currently have pending any request (including any
concurrently filed request) for a private letter ruling, cfrange in method of accounting, or technical advice? .
b
9a
x
x
N /A
NIA
N A
x
x
x
b lf "Yes," for each request atta
type of request (private letter
in the request(s).
ll ls the applicant requesting to
ch a statement providing the name(s) of the taxpayer, identification number(s), the
ruling, change in method ofaccounting, ortechnical advice), and the specific issue(s)
r\,
change its overall method of accounting?x
lf "Yes,'' check the appropriatr
accounting. Also, complete S
Present method:
Proposed method:
, boxes below to indicate the applicant's present and proposed methods of
:hedule A on page 4 of this form.
] Cash tr Accrual tr Hybrid (attach description)
] Cash t] Accrual n Hybrid (attach description)
N/A
Form 31 1 5 lPev t2 2009;
't2
a
b
c
d
13
Form 31 15 r2-2009)IDACORP INC 85-0505802
lf the applicant is either (i) not changing its overall method of accounting, or (ii) is changing its overall method of
accounting and also changing to a special method of accounting for one or more items, attach a detailed and
complete description for each of the following: SEE ATTACHMENT
The item(s) being changed.
The applicant's present method for the item(s) being changed.
The applicant's proposed method for the item(s) being changed.
The applicant's present overall method of accounting (cash, accrual, or hybrid).
Attach a detailed and complete description of the applicant's trade(s) or business(es), and the principal business
activity code for each. lf the applicant has more than one trade or business as defined in Regulations section
1.4441(d), describe: whether each trade or business is acmunted for separately; the goods and services
provided by each trade or business and any other types of activities engaged in that generate gross income; the
overall method ofaccounting for each trade or business: and which bade or business is requesting to change its
accounting method as part of this application or a separate application.SEE ATTACHMENT
'|.4 Will the proposed method of accounting be used for the applicant's books and records and financial statements?
For insurance companies, see the instructions
lf "No," attach an explanation.
3.d preceding
SEE ATT
15a Has the applicant engaged, or will it engage, in a transaction to which section 381(a) applies (e.9., a
reorganization, merger, or liquidation) during the proposed tax year of change determined without regard to any
potential closing of the year under section 381(b)(1)?
b lf "Yes," for the items of income and expense that are the subject of this application, attach a statement identifying
the methods of accounting used by the parties to the section 38'r(a) transaction immediately before the date of
distribution or transfer and the method(s) that would be required by section 381(cX ) or (cXS) absent consent to
the change(s) requested in this application.
16 Does the applicant request a conference with the IRS National Office if the IRS proposes an adverse response?
17 lf the applicant is changing to either the overall cash method, an overall accrual method, or is changing its method
of accounting for any property subject to section 263A, any long-term contract subiect to section 460, or
inventories subject to section 474, enter the applicant's gross receipts for the 3 tax years preceding the tax year of
change.
1st prec€ding
ytaa snded: mo yl
N/A
18 ls the applicant's requested change described in any revenue procedure, revenue ruling, notice, regulation, or
other published guidance as an automatic c-hange request? .
lf "Yes," attach an explanation describing why the applicant is submitting its request under advance consent
request procedures
19 Attach a full explanation of the legal basis supporting the proposed method for the item being changed. lnclude a
detailed and complete description of the Facts that explains how the law specifically applies to the applicant's
situation and that demonstrates that the applicant is auhorized to use the proposed method. lnclude all authority
(statutes, regulations, published rulings, court cases, etc.) supporting the proposed method. Also, include eiher a
discussion of the contrary authoriues or a statement that no contrary authority exists.
20 Attach a copy of all documents related to the proposed change (see instructions).
21 Attach a statement of the applicant's reasons for the proposed change.
22 lf the applicant is a member of a consolidated group for the year of change, do all other members of the
consolidated group use the proposed method of accounting for the item being changed?
lf "No," attach an explanation.
23a Enter the amount of user fee attached to this application (see instructions). > $
b lf the aoolicant oualifies for a reduced user fee. attach the reauired information or certification (see instructions
Does the applicable revenue procedure, revenue ruiing, notice, regulation, or other published guidance require the applicant to
implement the requested change in mothod of accounting on a cut-off basis ralher than a section 481 (a) ad.iustment?
lf "Yes," do not complete lines 25, 26, and 27 below.
Enter the section 48'l (a) adjustment, lndicate whether the adjustment is an increase (+) or a decrease (-) in
income. ) $ 0 Attach a summary of the computation and an explanation of the methodology
used to determine the section 48f (a) adjustment. lf it is based on more than one component, show the
computation for each component. lf more than one applicant is applying for the method change on the same
application, attach a list of the name, identification number, principal business activity code (see instructions), and
SEE ATTACHMENT
erde6: ?o
24
Form 31 1 5 ;Rev 12"200-a)
25
the amount of the section 48 attributable to each
a
b
IDACORP. INC 85-0s05802
secton the applicant elecl to take the
entire amount of he adjustnent into account in he year of change?.27 ls any part of lhe sec{ion 481(a) adjustment attibutable to transactions between members of an affillated group, a
consolidated group. a controlled group, or oher related parties?.
lf Yes,'attach an
Schedule A-Change ln Overal! lUlethod of Accountlng (lf Schedule A applies, Part I belour must be completed.) N/A
ln Overal! t[ethod
Enter the following amounts as of the dose of he tax year preceding the yoar of change. lf none, state "None." Also, attach a
stratement providing a breakdom of the amounts entered on llnes la through 'lg.
lncome accrued but not recelved (such as accounts receivable).
lncome received or r€ported before it was eamed (such as advanced payments). Attach a desoiption of
the income and the legal basis for the proposed method
Expenses accrued but not paid (such as accounts payable)
Prepaid expense previously deducted.
Supplies on hand previously deducted and/or not previously reported
lnventory on hand prevlously deducted and/or not previously reported. Complete Schedule D, Part ll
Other amounts (speciry). Attaci a description of the ltem and the legal basis for lts lnclusion in the
calculation of lhe section 481(a) adiustment. )
Net rection 481(a) adjuctment (Combine fines ia-is.j'inOicate whether th6 adjustrnent is an increase (+)
or decrease G) in income. Also enter the net amount of this section 481(a) adjustment amount on Part lV,
line 25.
2 ls the applicant also requesting the recuning item exception under section 461(hX3)? .] Ves f] to
3 Attacfi copies of the profit and loss statement (Sctedule F (Form 102l()) for hrmers) and the balance sheet, if applicable, as of
the close of the tax year preceding the year of change. Also attrach a statement specifuing the accounting method used when
preparing the balance sheet. lf books of account are not kept. attaci a copy of the business schedules submitted with the
Federal income trax retum or other retum (e.9.. tax-exempt organizatlon retums) for that pedod. lf the amounts in Part l, lines
1a through 19, do not agree with those shown on both the profft and loss statement and the balance sheet, attach a statement
explaining the differences.
to the Cash Mettod For Advance Consent instructions
Applicants requestng a change to the cash method must attach the following information:
1 A description of inventory items (items whose production, purchase, or sale is an income-produclng factor) and materials and
supplies used ln carrying out the business.
2 An explanatlon as to whether the aDplicant is required to use the accrual method under any section of the Code or regulatlons.
Schedule B-Change to the D€forral ilethod for Advance Payments (see instructions)
lf the applicant is rBquesting to change to the Deferral Method for advance payments described in section 5.02 of Rev. Proc.
2OO4-34,2004-1 C.B. 991, attach the following information:
A statemont explaining how the advance payments meet he definition in seclion 4.01 of Rev. Proc. 2004-34.
lf the applicant is filing under the automatic change procedures of Rev. Proc. 2OO8-52, the informatlon required by section
8.02(3)(a){c) of Rev. Proc. 20O4-U.
lf the applicant is filing under the advance consent provlsions of Rev. Proc. 97-27,lhe lnforrrratiori required by section
8.03(2[a[(f) of Rev. Proc. 2004-U.
lf the applicant is requesting to change to Ere defenal method for advance payments described in Regulations sec{ion
1.,151-s(bxl Xii). attach the following.
A statement explaining how the advance payments meet the definition in Regulations section 1.451-5(a[1).
A statement explaining what portions of the advance payments, if any, are attributable to services. whether such services are
integral to the provisions of goods or items, and whether any porlions of the advance payments that are atbibutade to
non-integral services are less than five percent of the total contract prices. See RegulaUons sections I .451 -s(ax2xi) and (3).
A statoment explalning that the advance payments will be included in income no lat€r than when included in gross receipts for
purposes of the applicant's financial reports. See Regulations section 1 .4ti1-S(bxl Xli).
A stratement explalning whether the inventoriable goods exceptlon of Regulations section 1.451-5(c) applies and if so, when
substantlal advance pafnents will be received under the contsacts, and how the exception will limit the deferral of income.
c
d
c
t
s
N/A
a
b
a
b
Form 3'115 {Rev, 12.2009)
Form 31 15 (Rev. '12-2009)IDACORP, INC,85-050s802 Page 5
a
b
c
d
Schedule C-Changes Vyathln the LIFO lnventory tlethod (see instructions)N/A
General LIFO lnformadon
Complete his sec{ion if the r€quest€d change involves changes wilhin the LIFO inventory method. Also, attaci a copy of all
Fonn. 970, Application To Use LIFO lnventory Mehod, ffled to adopt or e)eand he use of the LIFO method.
1 Attacft a description of the applicants present and proposed LIFO methods and submethods for each of the fiollowing
items:
Valulng inventory (e.9., unit mefiod or dollar-value method).
Poollng (e.9., by llne or type or class of goods, natural business unit multiple pools, raw material conl€nt, simplified dollar-
value method, inventory pdce index computation (lPlC) pools, vehicle-pool mehod. €tc,).
Pricing dollar-value pools (e.9.. doublo-extension, index, link-chain, llnk+hain index, lPlC method, etc.).
Determining the cunent-year cost of goods in the ending inventory (i.e., most recent acquisitions, earliest acquisitions during
the cunent year, average cost of cunent-year acquisilions, or other permitted method).
lf any present method or submethod used by the applicant is not the same as indlcated on Form(s) 970 ffled to adopt or
e)eand the use of the method, attach an explanatlon.
lf the proposed change ls not requested for all the LIFO invenbry, attach a statement sp€cifying the inventory to which the
change is and is not applicable.
lf the proposed change is not requested for all of he LIFO pools, attactr a statemant specifying he LIFO pool(s) to which the
change is applicable.
Attach a stiatement addressing whether the applicant values any of its LIFO inventory on a method other than cost. For
e,€mple, if the applicant values some of its LIFO inventory at retrail and the remainder at cost, ldentiry which lnventory items
are valued under each method.
lf cfianoinq to the lPlC method, attach a Form 970.
ln Poollng ln\rentoties
lf the applicant is proposing to change its pooling method or the number of pools, attiach a dsscription of the contents of, and
stato the base year for, each dollar-value pool the applicant presenty uses and prcposes to use.
lf the applicant is proposing to use natural business unit (NBU) pools or requesting to cfiange the number of NBU pools,
attact the following infomation (to the extent not already provided) in sufficient detail to show that each proposed NBU was
determined under Regulations section 1.472-8<bX1) and (2):
A description of the types of products produced by the applicanl lf posslble, attach a brochure.
A descrlption of the types of processes and raw materials used to produce the products in eaci proposed pool.
lf all of the products to be included in the proposed NBU pool(s) are not produced at one facility, state the reasons for the
separate facilities, the location of each facility, and a descriplion of the products eacfi facility produces.
A description of lhe natural business divisions adopted by the taxpayer. Stat€ whether separata cost csnters are maintained
and if separate profit and loss stiat€ments are prepared.
A statement addressing whether the applicant has inv€ntories of items purchased and held for resale that are not further
processed by the applicant, including whether such items, if any, will be included in any proposed NBU pool.
A statement addressing whether all items including raw materials, goods-in-process, and flnlshed goods entering into the
entire inventory investment for each proposed NBU pool are presently valued under the LIFO method. Describe any items that
are not pressntly valued under the LIFO method that are to be included in each proposed pool.
A statement addressing whether, wlthin the proposed NBU pool(s), there are items both sold to unrelated parties and
transferred to a different unit of the applicant to be used as a @mpon€nt part of another product prior to final processing.
lf the applicant is engaged in manufacturing and is proposing to use the multiple poolang method or raw material content
pools, attrach information to show that each proposed pool will consist of a group of items that are substantially similar. See
Regulations secton 1.472-8(b)(3).
lf the applicant is engaged in the wholesaling or retailing of goods and is requesdng to change the number of pools used,
attach infurmation to show that eacfi of the proposed pools is based on customary business classifications of the applicanfs
fade or business. See section 1
(Rev. l2-20m)
a
b
G
Form 31 15 (Rev. 12-2009)IDACORP. INC 85-0505802 Page 6
Schedule D--Ghange In the Treahrent of Long-Tom Contracts Under Section 460, lnventorles, or Otfter
Sectlon 263A Assets (see instructions N/A
ln Reoortino lncome From Lono-Term Contracts Part lll on 7 and 8.
I To tho extent not already provided, attach a description of the applicant's present and proposed melhods for reportng lncome
and expenses from long-term confacts. Also, attach a representative actual contract (without any deletlon) br the requested
change. lf the applicant is a constuction contractor, attacfi a detalled description of its construction activities.
lf line 2b is'No,'attach an explanation.
c lf line 2b is "Yes,'' is the applicant requesting to use the percentage-of-completion method using cost-to-
cost under Regulations section 1.46O4(b)? .[Vcs
d lf line 2c is "No," is the applicant requesting to use the exempt-contract percentagmf-completion
method under Regulations section 1.460-4{cX2P . . .flVes
lf line 2d is "Yes,' attach an explanation of what cost comparison the applicant will use to determine a
contract's com pletion factor.
lf line 2d is 'No," attaci an explanaUon of what method the applicant is uslng and the aulhodty br its use.
3a Does the applicant have long-term manufacturing contracE as defined in section 460(fX2P. .f]Ves Ettob lf Yes,' attach an explanation of the applicants present and proposed method(s) of accounting for longr
term m anufacluring conbacts.
c Attach a description of the applicants manufacturing acUvities, includlng any required installation of manufactured goods.
4 To determine a contracts completlon factor using the percentage-of-completion method:
2a Are the applicants contracts long-term conbacts as defined in section 460(0(1 ) (see insbuctions)?
b lf 'Yes," do all the contracts qualify for the exception under section ,160(e) (see instuctionsp
a Will the applicant use he cost-to-cost method an Regulations section 1.460-4(b)? f]Vesb lf line 4a is 'No." is the applicant electing the simplified cost-to-cost method (see section a60(b)(3) and
Regulations section 1.460-5(cD?. lVes5 Attach a siatement indicating wfiether any of he appllcanfs contracts are elther cost-plus long-term
lves flx"lves Em
Dtto
flxo
Erc
flmo
1
2
3a
b
contracts or Federal lono-lann contracts.
in Valuing lnventories Cost Alocation Part lll on 7 and 8.
Atlach a description of the inventory goods being changed.
Attach a description of the inv€ntory goods (if any) NOT being changed.
ls the applicant subject to section 263A? lf 'No," go to line 4a . . .EYo f]Xo
ls the applicants present inventory valuation method in compliance wilh section 263A (see instructions)?
lf "No,'attach a dotailed explanation Yas flno
4a Check the appropriate boxes below.
ldentifi cation methods:
Specific identification
FIFO
LIFO
Other (attach explanation )
Valuation methods:
Cost or market. whichever is lower
Retail cost
Retail, lower of cost or market
Other (attach explanation)
Enter the value at the end of the tax year preceding the year of change
a
b
lf the applicant ls changing from the LIFO inventory method to a non-LIFO method, attach the following information (see
instructions).
Copies of Form(s) 970 filed to adopt or expand the use of the method.
Only for applicants requesting adrEnce consent. A statement describing whether the applicant is changlng to the method
required by Regulations section 1.472-6(a) or (b), or whether tfie applicant is proposing a different method.
c Only for applicants requesting an .utomatic change. The statement required by sectlon 22.01(5) of the Appendix of Rev.
b
5
Proc. 2008-52 (or lts
(Rev.12-2009)
Form 3115 IOACORP, INC 8S0505802
fethod of Cost Alocadon (Comdete thb part if the requested dlange lnvolves either proparty sublect
to section 2634 or long-term oontracts as described in section 460 (see instruclions)).
Sectlon A-Alocatlon and Gapita lization tethods
Attacfi a descrlptlon (induding sample computations) of the pr$ent and proposed method(s) the applicant uses to capitalize direct
and indirect costs poperly allocable to real or tangible personal property produced and property acquired fur resale, or to allocate
and. where appropriate, capitalize direcl and indirect costs properly allocable b long-term contracts. lnclude a descrlption of the
method(s) used for allocating indirect costs to intermediate cost obj€cdves such as departments or activities prior to the allocatlon of
such cosb to longFterm contracts, real or tangible personal property produced, and property acquired br resale. The description
must include the following:
1 The method of allocating direct and indirect oosts (i.e., specific identification, burden rate, standard cost, or other reasonable
allocation method).
2 The method of allocating mixed service costs (i.e., direct reallocation, step-allocation, simpllfied service cost using the labor-
based allocation ratio, simplified ssrvice cost using the production cost allocaUon ratio, or other reasonable allocation
method).
3 The method of capitalizing additional section 263A costs (i.e., simplified production with or wlthout the hlstorlc absorption
ratio election, simplified resale with or without the histodc absorptlon ratio election includlng permlssible varlatlons, the U.S.
ratio, or other reasonable allocation method).
Sectlon B-Dlrect and lndirect Costs Required to be Alocated
Check the appropriate boxes showing the costs that are or will be fully included, to tho €xtent required, in the cost of real or tangible
personal propsrty produced or property acquired for reeale under section 263A or allocated to long-term contracts under section
t160. Mark'N/A'in a box if those costs are not incurred by the applicant. lf a box is not checked, it is assumed that those costs are
to the extent Attach an for boxes that are not ctrecked.
1
2
3
4
5
6
7
E
I
10
11
12
l3
14
t5
t6
17
18
t9
20
21
2i2
23
21
25
26
27
2E
Direct material
Direct labor
lndirect labor
Offcers'oompensation (not including selling activities) . . . .
Pension and other related cosb
Employs€ benefits
lndirect materials and supplies
Purchasing costs
Handling, processing, assembly, and repad<aging costs
Offsite storage and warehousing costs
Depreciation, amortlzation, and cost recovery allowance for equipment and facilities
placed in servlce and not temporarily idle
Depletion
Rent
Taxes other than state, local, and foreign income tax6s
lnsurance
Utilities
Maintenance and repairs that relate to a production, resale, or long-term conbact activity
Engineering and design costs (not including section 174 researcfi and experimental
expenses)
Rework labor, scrap, and spoilage
Tools and equipment
Quality control and inspection
Bidding expenses incurred in the solicitation of confacts awarded to the applicant . . . .
Licensing and ftanchise costs
Capitalizable service costs (inclu<ling mixed service costs)
Administrative costs (not induding any costs of selling or any rehim on capital)
Researcfi and exporimental expenses attibutrble to longFterm contracts
lnterest
Other costs a list of these costs.)
{Rev. 12-2009}
Sectlon C{ther Gosts Not Required To Be Alocated (Complete Secton C only if the applicant ls requesling to change its
Fdm 3'115 (Rov 12-2@)IDACORP. INC,85{505802 Page E
tethod of Cost Alocatlon
method br these
I Ma,teting, selling, adv€rtisirg, and distribution expenses
2 Researcfi and experim$tal expenses not includod in Section B, line 26
3 Bidding expenses not induded in Section B,line 22
tl Gsneral and administsative costs not induded in Section B
5 lncome taxes
6 Costofstrikes
7 Wananty and product liability costs
8 Section 179 costs
I Onsite storage
10 Depreciation, amortization, and cost recovery allowance not included in Section B,
line 11
11 Other costs a list of these costs.
Schedule E-Change ln Depreclafon or AmortlzaUon (see instruclions)
Appllcants requ$ting approval to change freir method of accounting lor deprecla0on or amortization complete this section.
Applicants ,rud provide this information for each item or class of property for which a change is reguested.
Jlote: See the Ust of A,ttomatic Accounting ,,etlnd Changes in the instuctions for informatton regading automatic changas
undersacfions5O 167, 168, 197, 14001, l40OL,orformerectlon 168. DonotfrleFoflit3llSwlthnspecttocertainlateelecfions
and election revocations (sre instuctions).
I lsdeproclaUonfurhepropertydetermlnedunderRegulatonssectionl.l6(a)-11(CLADR)? . I Ves EI rc
lf 'Yes," he only changes permitted are under Regulations section 1.16(a)-l 1(cXl Xiii). N/A
2 ls any of the depreciation or amorlization required to be capitalized under any Code section (e.9.. seclion
263A)?E Y". E tto
lf "Yes,' enter the eppliceble section > __________---_--_!j-3 -3 Has a depreciation, amortization, or expense election been made for the property (e.9., the elec{ion under
sections 168(fxl),179,or179Cp .[ Ves E Xo
lf 'Yes,'state the ele6{lon made >
tta To the extent not already proMded, attach a statement describing the prcperty being changed. lnclude in the description the
type of property, the year the property was placed in service, and the property's use in the applicants kade or business or
income-prcducing activity.SEE ATTACHMENT
b lf the property is residential rental property, dld the applicant live in the property bebre renting it? N/AE Yos fl }{"
c ls the property public utility property? .[] Ves f] no
5 To the extent not already provided ln the applicants description of its present method, attach a statBm€nt explaining how the
property is feated under the appllcants present method (e.9., depreciable property, inventory property. supplies under SEE
Regulations section 1.162-3, nondepreciable section 263(a) property, property deductible as a cunont exp€nses, etc.). ATTACH.
6 lf the proporty is not cunently treated as depreciable or amortizable property, attacft a statement of th€ facts supporting the
proposed change to depreciate or amortize the property. N/A
7 lf the proporty is curren0y treated and/or will be treated as depreciable or amortizable property, ptovide the following
information for both the present (if applicable) and proposed methods:SEE ATTACHMENT
The Code seclion under which the property is or will be depreciated or amortized (e.9., secton 168(g)).
The appllcable asset class fom Rev. Proc. 87-56, 1987-2 C.B. 674, for each asset depredated under seoton 168 (MACRS) or
under sectlon 1rt(X)L; the appllcable asset class from Rev. Proc. 83-35, 19891 C.B. 745, for each asset depreciated under
former section 168 (ACRS); an explanation why no asset class is identified br eactr asset for whicfi an asset class has not
been identified by the applicant.
The facts to support the asset dass for the prcposed method.
The depreciation or amortization method of the property, induding the applicable Code section (e.9., 200% dedining balance
method under section 168(b[1)).
The useful life, recovery period, or amortization period of the proper$.
The applicable convention of the property.
A statement of whefier or not the additional first-year special depreciation allowance (for example, as provided by section
168(k), 168(l), 168(m), 168(n). 1400L(b), or 1,l()ON(d)) was or will be claimed tor the property. lf not also provlde an explanation
a
b
c
d
e
f
s
as to whv no allowance was or will be claimed.
IDAIIO POWER COMPANY
ATTACHMENT TO FORM 3115
a) Parent Corporation:
b) FErN:c) Address
d) Under Exam:
Part II.0uestion 9(b)
IDACORP,Inc.
85-0505802
l22lW.Idaho St.
Boise, Idaho 83702
2012CAP Program
EIN:82-01309t0
FYD:1213112013
Part I. Name of Applicants
This Application is being filed by IDACORP, Inc. [EIN: 854505802] on behalf of itself and the
following subsidiaries (collectively hereinafter "Applicant'):
Applicant EIN
IDACORP.Inc.85-0505802
Idaho Power Company 824130980
Part I. Line 2
Pursuant to Appendix Section 6.32(3\ of Rev. Proc. 2011-14 (as added by Section 5.03(6) of Rev. Proc.
2Al2-20), the scope limitations contained in Section 4.02 of Rev. Proc. 2011-14 do not apply to taxpayers
that make this change for their first or second taxable year beginning after December 3 I , 201 1 .
Part II. Ouestion 6 - Parent Under Examination
Idatro Power Company (EIN: 82-0130980) changed its method of accounting for defining the
units of property used to determine whether they have disposed of tangible property for
depreciation purposes under the automatic corisent provisions of Rev. Proc. 2008-52 as modified
by Rev. Proc. 2009-39 for the taxable year ended'Decernber 31,2009.
Idaho Power Company (EIN: 82-0130980) changed its method of accounting for repair and
maintenance expenses under the automatic consent provisions of Rev. Proc. 2008-52 as modified
by Rev. Proc. 2009-39 and Rev. Proc. 20ll-14 for the torable year ended December 31, 2009.
Idaho Power Company (EIN: 82-0130980) changed its method of accounting for asset retirernent
obligations for the tax year ending December 31, 2009.
Idaho Power Company (EIN: 82-0130980) changed its rnethod of accounting for repair
expenditures pursuant to Rev. Proc. 2011-43 and Rev. Proc. 20ll-14 for the tax year ending
December 31, 2011.
Part II. Ouestion 12
a. The Applicant is making a late general asset account ("GAA") election under I.R.C. $ 168(iXa) and
Treas. Reg. $$ 1.168(i)-l and 1.168(i)-lT. Specifically, the Applicant is making the late GAA
election for all linear electric transmission and distribution ("T&D") assets (described below in
further detail) placed in service by the Applicant between January l, 1987 and December 31, 2011.
The Applicant is also making a late election to recognize gain or loss on the disposition of certain
Page I
IDAHO POWER COMPANY
ATTACHMENT TO FOR]VI 31 15
EIN: t2-01309t0
FYE:1213112013
assets that are the subject of the late GAA election in accordance with Treas. Reg. $ 1.168(D-
lT(eX3Xii). The collective purpose of these elections is to: (1) not deduct casualty losses related to
the assets that are the subject of this request, whether or not such losses were deducted by the
Applicant prior to January l, 2013; (2) deduct losses upon non-casualty-related dispositions (e.g.,
retirements) of the assets that are the subject of this request if the Applicant capitalized the associated
replacement costs as improvements under I.R.C. $ 263(a) prior to January l, 2013; (3) not deduct
losses upon non-casualty related dispositions of the assets that are the subject of this request if the
Applicant deducted the associated replacement costs as repair and maintenance undsr I.R.C. $ 162
and Treas. Reg. 1.1624; and (4) maintain otherwise deductible repair and maintenance costs that are
not required to be capitalized under Treas. Reg. $ 1.263(a)-3T(0(lxi)-(iii) or Treas. Reg. 1.263(a)-
3(kxl Xi)-(iii), as applicable.
b. Under its present method of accounting, the assets that are the subject of this rcquest are grouped for
tax depreciation purposes and individually retired. The Applicant depreciates such assets under
MACRS using the 200Yo or 150% declining balance or straight-line method, the appropriate recovery
period (as provided in Rev. Proc. 87-56) and the applicable convention (midquarter, half year, or
mid-month). The Applicant claimed the additional first-year depreciation deduction under I.R.C. $
168(k) for eligible property.
-- -- -The+pplicasrsdid not deduct casualty losses associated with the linear electric T&D assets that are
the subject of this request even thougb the Applicants may have suffered casualty losses prior to
January 1,2013.
With certain exceptions, the Applicant reports gain or loss on non-casualty-related dispositions of the
assets that are the subject of this request in the year of such disposition if the Applicant capitalized the
associated replacernent costs as improvements under I.R.C. $ 263(a) and Rev. Proc. 2011-43 (i.e., if
the Applicant replaced 10% or more of a unit of linear property). The Applicant does not re,port gain
or loss on non-casualty-related dispositions of the assets that are the subject of this request in the year
of such disposition if the Applicant deducted the associated replacement costs as repair and
maintenance under I.R.C. $ 162, Treas. Reg. 1.162-4, and Rev. Proc. 20ll-43 (i.e., if the Applicant
replaced less than l0% of a unit of linear property).
c. Under its proposed method of accounting, the Applicant will make a late GAA election under Treas.
Reg. $ 1.168(i)-1T with respect to the assets that are the subject of this request. Specifically, the
Applicant will put each asset that it accounts for as a separate retirement unit for Federal Energy
Regulatory Commission (*FERC") rcporting purposes in a separate GAA. For example, each of the
following assets will be included in a separate GAA:
o Foundations and Towerso Poles (Wood, Steel, Concrete), Stubs, and Foundationo Conductor (Copper or Aluminum-two continuous spans between 3 or more poles or
structures)o Set oflnsulatorso Set of Lightning arrestorso Disconnect Switches. Reclosero Line Transfonnerso Regulatorso Capacitor bank
Page2
IDAHO POWER COMPANY
ATTACHMENT TO FORM 3115
EIN:82-0130980
FYEz 12/3112013
o Serviceso Meterso Street Lights
Each GAA will be compliant with Treas. Reg. $ 1.168(i)-1T(c) insofar as each GAA will comprise a
single asset.
The Applicants will account for dispositions of the assets for which the late GAA election is made
consistent with Treas. Reg. $ 1.168-lT(e)(2) (e.g., the Applicants will continue to not deduct casualty
losses with respect to the assets that are the subject of this request), unless the Applicants elect to
recognize gain or loss upon disposition of the assets for which the late GAA election is made pursuant
to Treas. Reg. $ 1.168(i)-lT(e)(3xii).
The Applicants will make a late election to recognize gain or loss upon the non-casualty-related
dispositions of the assets for which the late GAA election is made pursuant to Treas. Reg. $ 1.168(i)-
1T(e)(3)(ii), however, the Applicants will not make this election if the associated replacement costs
represent repair and maintenance costs under I.R.C. $ 162, Treas. Reg.$ 1.1624, andRev. Proc.
201143. For example, if the Applicants replace linear T&D assets that collectively represent less
than 10% of the associated unit of linear property as determined under Rev. Proc. 201143, the
Applicants will.not make a late election to recognize loss upon the retirement of the existing linear
T&D assets.
d. The Applicant's overall method of accounting is an accrual method.
Part II. Ouestion 13
Idaho Power Company is a regulated electric utility engaged in the production, transmission, distribution,
and sale of electric energy throughout ldaho and Eastem Oregon. The principal business activity cqde is
221100.
Part II. Ouestion 14
The Applicant will not use the proposed method of accounting for their books and records and financial
statements as this method of accounting does not conform to Generally Accepted Accounting Principles
(GAAP).
Part IV. Ouestion 25
Pursuant to Appendix $ 6.32(aXa) of Rev. Proc. 2011-14, as amended by Rev. Proc-2012-20, the change
specified in Appendix Section 6.32(1(a)(i) of Rev. Proc. 2011-14, as amended by Rev. Proc.2012-20, for
MACRS property disposed of by the taxpayer prior to the beginning of the year of change is made with
an IRC $ a8l(a) adjustment. Similarly, the change specified in Appendix Section 6.32(1Xa)(ii) of Rev.
Proc. 201l-14, as amended by Rev. Proc.2012-20, is made with an IRC $ a8l(a) adjustment.
Entitv EIN IRC E 481(e) Adiustment
ldaho Power Comoanv 82-0130980 s0
Total $0
Page 3
IDAHO POWER COMPAI\IY
ATTACHMENT TO FORM 3115
EIN:82-0130980
FYEz L2l3ll20l3
Schedule E. Ouestions 4a. 5 and 7 - Description of Propertv
See the response to Part tr, Question 12.
Statement Rmuired bv Aooendix Section 632{4Xc} of Rev. Proc. 20ll-14
The Applicant will establish separate GAAs for each FERC retirement unit located at in its service area
that was placed in service between January 1,1987 and December 31, 2011.
For example, Idaho Power Company will have the following GAAs for linear electric T&D property that
was placed in service in the state of Idaho in a given tax year:
Statement Required bv Appendix Section 632(4Xil of R€v. Pro€.2011-14
The assets which are the subject of this request are identical to the assets identifred above in the statement
required by Appendix Section fi2($(c) of Rev. Proc. 2011-14.
Statement Required bv Apoendix Section 632(4Xe) of Ren Proc.20ll-14
The Applicant consents to, and agrees to apply, all of the provisions of Treas. Reg.$$ 1.168(i)-1 and
1.168(i)-lT to the assets that are subject to the election specified in Appendix Section 6.32(1)(a)(i) of
Rev. Proc. 20ll-14.
Except as provided in Treas. Reg. $$ 1.168(i)-1T(c)(1)(ii)(A), (eX3), (g), or (h), the election made by the
Applicant under Appendix Section 6.32(1XaXi) of Rev. Proc. 201l-14 is irrevocablc and will be binding
on the Applicant for computing taxable income for the year of change and for all subsequent taxable years
with rcspect to the assets that are subject to this election.
Strtement Reouired bv Aopendix Section 6.32(4Xf) of Rev, Proc. XOl l-14
Entity Asset/Location
Idaho Power Company (EIN: 82-0130980)Each foundation and tower
Each pole (Wood, Steel, Concrete), stub,
and foundation
Each span of conductor (Copper or
Aluminum-two continuous spans between
3 or more poles or structures)
Each insulator
Each lightning arrestor
Each disconnect switch
Each recloser
Each line transformer
Each regulator
Each capacitor bank
Each service
Each meter
Each street lisht
IDAHO POWER COMPANTY
ATTACHMENT TO FORM 3115
Applicant' s Fax Number:
Authorized Representative's
Fax Number:
EIN:82-0130980
I-YE,z l2l3tl20l3
The Applicant agrees to the following terms and conditions-
(r) a normalization method of accounting (within the meaning of I.R.C. $ 168(i)(9) will be used for
the public utility property subject to the application;
(ii) within 30 calendar days of filing the federal income tax retum for the year of change, the Applicant
will provide a copy of the completed application to any regulatory body having jurisdiction over the
public utility property subject to the application;
(iii) and as of the beginning of the year of change, the Applicant will adjust its deferred tax reserve
account or similar account in the taxpayer's regulatory books of account by the amount of the
deferral of federal income tax liability associated with the I.R.C. $ 481 (a) adjushent applicable to
the public utility property subject to the application.
Reouest for Facsimile Transmission Pursuant to Section 9"04(3) of Rev. Proc. 2013-1
ln accordance with the procedures set forth in section 9.04(3) of Rev. Proc. 2013-1, the Applicant
requests that a copy of any document related to this request (e.9., a request for additional information) be
provided to the Applicant and the Applicant's authorized representatives via fax at the nrunbers below:
Gene Maxchioro
Robert Kilinskis
Eric Peel
(208) 388-s460
(202\ 66t-t29s
Qt2) 653-26s4
Page 5
," 2848
(Rev. March 2012)
Departnenl of tho Trasuy
lntomd Rswnue Servico
Taxpayer name and address
IDACORP, INC,
P,O BOX 70
Name and address
ROBERT KILINSKIS do DELOITTE TAx LLP
555 12TH STREET NW. SUITE 5OO
WASHINGTON, DC 2OOA4 -1 2A7
Check if to be sent notices and communications
Name and address
ERIC PEEL
3 SECOND STREET, HARBORSIDE PLAZA 1O
JERSEY CITY, N] 07311
Check if to be sent notices and communir:ations
Name and address
DENISE CARMICHEAL clo DELOITTE
555 12TH STREET NW, SUITE 5OO
TAX LLP
) Type or print ) See the aepaalo instructims.
Power ol Attorney
Caution: A *parate Form 2848 sltould be comphted for each taxpayer. Form 2il8 will not be honored
for any purpose other than rcprcsentation before tDe /PS.
inforrnation.must slon and date this form on 2,line7.
Power of Attomey
and Declarataon of Representatlye
Taxpayer identifi cation number(s)
85-0505802
OMB No.1545-0150
For IRS Us. Only
Rmeived by:
Nme
Telephone
Function
Dafe
83707
appoints the follot,vlng representative(s) as attorney(s)-in-fact:
Representative(s) must sign and date this lorm on page 2, Part ll.
Plan number (if
CAF No-
Check if new: Address
Check if new: Address
No.Fax l',1o.
Fax No.
CAF No,
prN
- "--. ------ ii.f :-f :-ql*.o---.-.-...--..-:-.-
relephone N o. - - _-- - _ - _ " - _? -0-? :!-7-9: !"92_5-. - -- - _ - - - - "
Fax No.
T
WA DC 20004-1207
to represent the taxpayer before the lnternal Revenue Servicr for the followlng matters:
3 Matters
Description of Matter (ncome, Eflployment, Payroll, Excls€, Estate, Glft, Whistleblower,
Practition* Dsciplh€, PLB, FOIA, Clvil Penatty, Etc.) (see instrudions for line Q
INCOME
Specific use not recorded on Centralizcd Authodzation File (CAR. lf the power ol
check this box. See the instructions for Line 4. Specilic Uses Not Recordcd on CAF
242-661 -152a
No.Fax No.
Yea(s) or Period(s) (if applicable)
(see instructions for line 3)
aftorney ls for a specific use not recorded on CAF,a
Acts autho?lzcd. Unless otherwise provlded below, the representatives generally are authorized to receive and inspect conridential tax
information and to peform any and all acts that I can perform wlth respect to the tax matt€rs described on line 3, for example, the authority to
sign any agreements, consents, or other documents. The representative(s), however, is (are) not authorized to receive or negotiate any
amounts paid to the client in connection with this representation (including refunds by either electronic means or paper checks). Additionally,
unless the appropriate box(es) below are checked, the representative(s) is (are) not authorized to execute a requesit for disclosure of tax returns
or retum informatlon to a third party, substitute another representative or add additional representatives, or sign certaln tax retums.
! Disclosure to third panies; E Substitute or add representatlve(s); E Sbnlng a return;
Ll Other acts authorized:
Daytlme telephone numbot
202-879-4995
Tax Form Number
0 040, 941, 720, etc.) 0f applicable)
(see instructions ror more information)
Exceptions. An unenrolled return preparer cannot sign any document for a tlxpayer and may only represent taxpayers in limited situatlons.
An enrolled actuary may only represent taxpayers to the extent provided in section 10.3(d) of Treasury Department Circular No. 230 (Chcutar
230). An enrolled retirement plan agent may only represent taxpayers to the extent provided in section 1 0.3(e) of Circular 230. A registered tax
return preparer may only represent taxpayers to the extent provlded in section 10.3(f) of Circular 230. See the line 5 instructions for restrictions
on tax matters partners. ln most cases, the student practitioner's (level k) authority is limited (for example, they may only practice under the
superuision of another practitioner).
Ust any specific deletions to the acts otherwise authorized in this power of attorney: rHlS-P-o-wE1-9-t-AlI9Ey-F-Y-lS_!llY!-IF-9--f9-f!-Ll.!!-g-l-.
DELOITTE TAX CANNOT RECEIVE FUNDS ON BEHALF OT TAXPAYER OR PAY IIS LIABILITIES.
For Privacy Act atrd Pap.rwoik Reductbn Act Notlce, see tho instructions. Cat. No. 1 1 gBoJ form 2&{8 (Rev. a-zotz)
Form 2848 (Rev. 3-2012)Pare2
I Retrntbn/revocation of prlor power{s) of attornoy. The flling of this power of attomey automatlcally revokes all earlier powe(s) of
attorney on flle with the lntemal Revenue Service for the sam€ matters and years or periods cover€d by this document. lf you do not want
to r6/oke a prlor power of attomey, check here
YOU MUST ATTACH A COPY OF ANY POWER OF ATTORNEY YOU WANT TO REMAIN IN EFFECT.
7 Srgnsturc ol tarpayer. It a tax matter concems a year in which a ioint retum was flled, the husband and wife must each ftle a separate power
of attorney even if the same rspr€sentatlve(s) is (are) being appolnted. lf signed by a corporatE offfcer, partner, guardian, tax matters partner,
executor, receiver, administrator, or trustee on behalf of the taxpayer, I certify that I have the authority to exocute this form on behalf of the
ta)(payer.
> IF NOT SIGNED AND DATED, THIS POWER OF ATTORNEYWLL BE RETURNED TO THE TNOAYER.
Print Name
TITTD
PIN Number
VP AND TREASLIRER""'-----' iir6 mi;tri;;iii,;i'
"-.F-,iLtilffi ;ttpU;id;-fi -niiiiiJtri-dii-riili;Atviadi'-..STEVEN R. KEEN
Under penatties of periury, I dEclare that:
o I am not cunently under suspension or disbament from practice before the lntemal Bevenue Service;
. I am aware of regulatlons contained in Circular 230 (31 CFR, Part 10), as amended, conceming practice before the lntemal Revenue Servlce;
. I am authorlzed to represent the taxpayer &JentifM in Part I forthe mattds) specified th6re; and
. I am one of the following:
a Attomey-a member in good standing of the bar of the highest court of the iurisdiction shown below.
b CertifiEd Public Accountant-duly qualified to practice as a certified public accountairt in the jurisdiction shown below.
c Enrolled Agent-enrolled as an agent under the roquiremgnts of Circr.rlar 230.
d Offlcer-a bona ftde officer of the taxpayer's organization.
e Full-Time Employee-a full-tlme employee of the taxpaysr.
t Family Member-a member of the taxpayer's lmmediate family (for example, spouse, parent, child, grandparent, grandchild, step-parent, step-
child, brother, or sbter).
g Enrolled Actuary-enrolled as an actuary by the Joint Board for the Enrollment of Actuaries under 29 U.S.C. 1242 fthe authority to practice before
the lnternal Revenue Service is limited by section 10.3(d) of Circular 230).
h Unenrolled Return Preparor-Your authority to practice before the lntemal Revenue Service is llmhed. You must have been eligible to slgn the
return under examlnation and have slgned the retum. See Notice 2011-6 and Speclal ruhs for registelEd tax ret[rr prcParers and unenrolled
Tetum prrapr€rs in the instnEtions.
I Begistered Tax Retum Preparer-registered as a tax retum pr€parer under the requirernents of section 10.4 of Circular 230. Your authority topractice before the lrternal Re\renue Service is limited. You must have b€€n eligible to sign the retum under examlnation and have slgned thereturn. Src Noticc 2011-6 ard Speclal ru!6s lor registored tax rltum preparere and unenrolled retum prepners an the instructaons.
k Student Attomey or CPA-receives permission to practice before the IRS by vlrtue ol his/her status as a law, business, or accounting student
working in LITC or STGP under section 10.7(d) of Circular 230. See instnrctions for Pan ll for additional information and requirements.
r Enrolled Retirement Plan Agent-enrolled as a retirement plan agent under the requirements of Circular 230 (the authority to practice before the
lntemal Fbvenue Service is limited by section 10.3(e).
> IF THIS DECLARATION OF HEPRESENTATIVE IS NOT SIGNED AND DATED, THE POWER OF ATTORNEY wlLL BE
RETURNED. REPRESENTATIVES MUST SIGN lN THE ORDER LISTED lN LINE 2 ABOVE. See the instructions for Part ll.
Note: For designations d-f, 6nter your title, position, or relationship to the taxpayer ln the "Licensing iurisdiction" column. See the instructions ior Part llfor more information.
Designation - lnseft
above letter (a-rl
Licensing jurisdictlon
(state) or other
licensing authority
(if applicable)
lar, license, certification
registration, or
enrollment number
(if applicablel. See
nstructions for Part ll fo
more information.
Signature Date
b IL 065-01 7374
NY 084653
0008791 5-EA
Form 2848 (Rev. 0-2012)