The circumstances give rise to EADIT are identical to those which give rise to ADIT, and these balances should be treated consistently. We note the testimony of OCA witness Morgan who stated, because the name of the account in which these “just funds are held has changed, ratepayers should not be penalized by not including the funds in the rate base given the funds are still restricted as if they were protected ADIT.” OCA St. 1 at 13. We also find value in I&E’s testimony on this issue. I&E witness Wilson stated that the fact that the EADIT is no longer due in future income tax payments but is now due to ratepayers via a refund over the remaining useful life of affected plant, does not change the fact that the Company has received this money from ratepayers in prior years, and the money has been available for infrastructure improvements. Witness Wilson explained that the original intent should be considered, and that because the funds were an interest-free loan from the government (taxes due at some point in the future), and now due to the reclassification, the money is basically an interest-free loan from ratepayers, the ratepayers should not be required to pay the Company a return on this balance during the time it takes to refund the money to them. I&E St.1 at 38. Further, as the OSBA explained, both ADIT and EADIT are balances reflecting tax costs included in rates but not paid out by the Company. The only difference between ADIT and EADIT is that ADIT represents the balance of taxes included in rates that the Company will eventually need to pay to the government, and EADIT represents the balance of taxes included in rates which will no longer need to be paid to the government because of the TCJA and will be refunded to ratepayers. ADIT and EADIT are the same in that they represent taxes which have been paid by ratepayers, but which have not been paid to the government or refunded to customers. We agree with the OSBA that given the obvious and close parallels between ADIT and EADIT and the substantial differences between unamortized expense and EADIT, EADIT is not an unamortized expense and should be treated consistently with ADIT and therefore
The circumstances give rise to EADIT are identical to those which give rise to ADIT, and these balances should be treated consistently. We note the testimony of OCA witness Morgan who stated, “just because the name of the account in which these funds are held has changed, ratepayers should not be penalized by not including the funds in the rate base given the funds are still restricted as if they were protected ADIT.” OCA St. 1 at 13. We also find value in I&E’s testimony on this issue. I&E witness Wilson stated that the fact that the EADIT is no longer due in future income tax payments but is now due to ratepayers via a refund over the remaining useful life of affected plant, does not change the fact that the Company has received this money from ratepayers in prior years, and the money has been available for infrastructure improvements. Witness Wilson explained that the original intent should be considered, and that because the funds were an interest-free loan from the government (taxes due at some point in the future), and now due to the reclassification, the money is basically an interest-free loan from ratepayers, the ratepayers should not be required to pay the Company a return on this balance during the time it takes to refund the money to them. I&E St.1 at 38. Further, as the OSBA explained, both ADIT and EADIT are balances reflecting tax costs included in rates but not paid out by the Company. The only difference between ADIT and EADIT is that ADIT represents the balance of taxes included in rates that the Company will eventually need to pay to the government, and EADIT represents the balance of taxes included in rates which will no longer need to be paid to the government because of the TCJA and will be refunded to ratepayers. ADIT and EADIT are the same in that they represent taxes which have been paid by ratepayers, but which have not been paid to the government or refunded to customers. We agree with the OSBA that given the obvious and close parallels between ADIT and EADIT and the substantial differences between unamortized expense and EADIT, EADIT is not an unamortized expense and should be treated consistently with ADIT and therefore