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Oklahoma Corporation Commission approves IRS reconsideration letter and clears PSO Private Letter Ruling request
Summary
On Aug. 26, 2025 the Oklahoma Corporation Commission unanimously approved a reconsideration letter to the IRS about Private Letter Ruling 105952-22 and authorized Public Service Company of Oklahoma to submit a Private Letter Ruling request with conditions requiring coordination and timely notice to parties.
The Oklahoma Corporation Commission unanimously approved a letter to the Internal Revenue Service asking it to reconsider Private Letter Ruling 105952-22 and authorized Public Service Company of Oklahoma to submit a Private Letter Ruling request with specified conditions, the commission recorded in a vote Aug. 26, 2025.
The action took place at a continued session of the commission’s Aug. 20 meeting in the Concourse Theater at the Will Rogers Memorial Office Building in Oklahoma City. The agenda item is recorded in Case No. PUD2024-000032 and relates to Order No. 738226 and Final Order No. 749853.
Commissioner Kim David moved that the commission approve the reconsideration letter in its current form, direct the commission secretary to add signatures, instruct Public Utility Division staff to coordinate with retained counsel Michael R. Fontham and commission offices to submit the signed letter to the IRS, and file a copy in the electronic case file. The motion passed unanimously (Commissioners David, J. Todd Hiett and Brian Bingman voting “Aye”).
Commissioner David then moved that the commission approve PSO’s proposed Private Letter Ruling request as edited by the commission offices and direct PSO to finalize and submit the request to the IRS with the commission’s response attached first, followed by attachments from the Oklahoma Attorney General and the Oklahoma Industrial Energy Consumers (OIEC), and Order No. 749853 attached last. The motion requires PSO to provide a complete copy of the submission to the commission offices and parties who have signed confidentiality agreements and to notify the commission and parties within two business days if the IRS asks questions. The motion additionally instructs that parties must be given an opportunity to attend any IRS meeting with AEP/PSO discussing the request. That motion passed unanimously.
Michael R. Fontham, the commission’s retained counsel, participated by Zoom during the continuance. Commissioners discussed draft letters and the form of PSO’s submission before voting to continue and then finalize direction at the Aug. 26 session. The minutes note no vote was taken on the matter during the Aug. 20 session, when the item was continued to Aug. 26 for further consideration.
The votes direct administrative steps rather than substantive changes to the referenced IRS ruling: they (1) approve the commission’s reconsideration letter and submission process, (2) approve PSO’s PLR request with specified attachments and cover pages, and (3) require timely notice to the commission and parties and an opportunity for parties to participate if the IRS requests meetings with AEP/PSO. No changes to Final Order No. 749853 were recorded at the Aug. 26 vote.
Case No. PUD2024-000032, the commission’s filings and related orders are available in the commission’s electronic case file for review.
