Court of Appeals for the D.C. Circuit October 18, 1985, 83-2059 (City of Charlottesville, Virginia v. Federal Energy Regulatory Commission)

Opinion for the Court filed by Circuit Judge SCALIA.

SCALIA, Circuit Judge:

Each year since 1947, Columbia Gas System, Inc. (“Columbia System”), a public utility holding company, has filed a consolidated federal income tax return on behalf of itself and its subsidiaries, pursuant to the Internal Revenue Code of 1954, 26 U.S.C. § 1501 (1982).