I.L.M. 200940018 (Jun. 23, 2009)

(payments that a utility company receives as reimbursement for costs incurred in relocation of transmission facilities to accommodate municipal development projects are not, consistent with I.R.S. Notice 87-82, 1987-2 C.B. 389, non-shareholder contributions to capital under I.R.C. Sec. 118(a); amounts includible in income).