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Income Taxes | 12 Months Ended
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Dec. 31, 2019
Income Taxes [Line Items] |
Income Taxes | Income Taxes CMS Energy and its subsidiaries file a consolidated U.S. federal income tax return as well as a Michigan Corporate Income Tax return for the unitary business group and various other state unitary group combined income tax returns. Income taxes are allocated based on each company’s separate taxable income in accordance with the CMS Energy tax sharing agreement. In December 2017, the TCJA was enacted, which changed existing federal tax law and included numerous provisions that affect businesses, with the primary impact being a reduction of the corporate tax rate from 35 percent to 21 percent. Presented in the following table is the difference between actual income tax expense on continuing operations and income tax expense computed by applying the statutory U.S. federal income tax rate:
In Millions, Except Tax Rate |
Years Ended December 31 | 2019 |  | 2018 |  | 2017 |
CMS Energy, including Consumers |  |  |  |  |  |
Income from continuing operations before income taxes |  | $ | 829 |  |  | $ | 774 |  |  | $ | 886 |
Income tax expense at statutory rate |  | 174 |  |  | 163 |  |  | 310 |
Increase (decrease) in income taxes from: |  |  |  |  |  |
State and local income taxes, net of federal effect 1 |  | 48 |  |  | 46 |  |  | 26 |
TCJA excess deferred taxes 2 |  | (31 | ) |  | (26 | ) |  | — |
Production tax credits |  | (20 | ) |  | (14 | ) |  | (8 | )
Accelerated flow-through of regulatory tax benefits 3 |  | (13 | ) |  | (39 | ) |  | (39 | )
Research and development tax credits, net 4 |  | (2 | ) |  | (11 | ) |  | (1 | )
Impact of the TCJA 5 |  | — |  |  | (4 | ) |  | 148 |
Other, net |  | (9 | ) |  | — |  |  | (12 | )
Income tax expense |  | $ | 147 |  |  | $ | 115 |  |  | $ | 424 |
Effective tax rate |  | 17.7 | % |  | 14.9 | % |  | 47.9 | %
Consumers |  |  |  |  |  |
Income from continuing operations before income taxes |  | $ | 928 |  |  | $ | 847 |  |  | $ | 971 |
Income tax expense at statutory rate |  | 195 |  |  | 178 |  |  | 340 |
Increase (decrease) in income taxes from: |  |  |  |  |  |
State and local income taxes, net of federal effect 1 |  | 53 |  |  | 51 |  |  | 30 |
TCJA excess deferred taxes 2 |  | (31 | ) |  | (26 | ) |  | — |
Accelerated flow-through of regulatory tax benefits 3 |  | (13 | ) |  | (39 | ) |  | (39 | )
Production tax credits |  | (12 | ) |  | (12 | ) |  | (8 | )
Research and development tax credits, net 4 |  | (2 | ) |  | (11 | ) |  | (1 | )
Impact of the TCJA 5 |  | — |  |  | 1 |  |  | 33 |
Other, net |  | (5 | ) |  | — |  |  | (16 | )
Income tax expense |  | $ | 185 |  |  | $ | 142 |  |  | $ | 339 |
Effective tax rate |  | 19.9 | % |  | 16.8 | % |  | 34.9 | %
1 | In 2017, CMS Energy completed the evaluation of its methodology for the state apportionment of Consumers’ electricity sales to MISO, taking into account recent state tax law developments in the electric utility sector. To recognize the anticipated refund and the impact of the expected lower effective tax rate on their deferred state tax liabilities, CMS Energy, including Consumers, recorded a $14 million income tax benefit in 2017. These tax benefits were net of reserves for uncertain tax positions and primarily
attributable to Consumers. In 2018, CMS Energy amended its 2013 Michigan Corporate Income Tax return and submitted a refund claim for taxes previously paid. The refund claim was denied by the State of Michigan. In 2019, CMS Energy received an unfavorable informal conference decision and filed a petition with the Michigan Tax Tribunal. A trial is anticipated in 2020. CMS Energy’s uncertain tax position on this matter remains unchanged.
2 | In December 2017, Consumers remeasured its deferred tax assets and liabilities at the new federal tax rate enacted by the TCJA and recorded a net $1.6 billion regulatory liability. As a result of an order received in September 2019, Consumers began refunding these excess deferred taxes to customers. For additional details on the order received, see Note 3, Regulatory Matters.
3 | In 2013, the MPSC issued an order authorizing Consumers to accelerate the flow-through to electric and gas customers of certain income tax benefits associated primarily with the cost of removal of plant placed in service before 1993. Consumers implemented this regulatory treatment beginning in 2014, with the electric portion ending in 2018 and the gas portion continuing through 2025.
4 | In March 2018, Consumers finalized a study of research and development tax credits for the tax years 2012 through 2016. As a result, Consumers recognized an $8 million increase in the credit, net of reserves for uncertain tax positions, at that time.
5 | In December 2017, CMS Energy and Consumers recorded a reasonable estimate to measure and account for the impact of the TCJA. In December 2018, CMS Energy recorded a true-up of their estimate and eliminated the $9 million valuation allowance on the sequestration of alternative minimum tax credits.
Presented in the following table are the significant components of income tax expense on continuing operations:
In Millions |
Years Ended December 31 | 2019 |  | 2018 |  | 2017 |
CMS Energy, including Consumers |  |  |  |  |  |
Current income taxes |  |  |  |  |  |
Federal |  | $ | (31 | ) |  | $ | (67 | ) |  | $ | — |
State and local |  | 28 |  |  | — |  |  | 6 |
|  | $ | (3 | ) |  | $ | (67 | ) |  | $ | 6 |
Deferred income taxes |  |  |  |  |  |
Federal |  | $ | 97 |  |  | $ | 112 |  |  | $ | 368 |
State and local |  | 32 |  |  | 58 |  |  | 36 |
|  | $ | 129 |  |  | $ | 170 |  |  | $ | 404 |
Deferred income tax credit |  | 21 |  |  | 12 |  |  | 14 |
Tax expense |  | $ | 147 |  |  | $ | 115 |  |  | $ | 424 |
Consumers |  |  |  |  |  |
Current income taxes |  |  |  |  |  |
Federal |  | $ | 107 |  |  | $ | 6 |  |  | $ | 159 |
State and local |  | 41 |  |  | 13 |  |  | 17 |
|  | $ | 148 |  |  | $ | 19 |  |  | $ | 176 |
Deferred income taxes |  |  |  |  |  |
Federal |  | $ | (10 | ) |  | $ | 60 |  |  | $ | 120 |
State and local |  | 26 |  |  | 51 |  |  | 29 |
|  | $ | 16 |  |  | $ | 111 |  |  | $ | 149 |
Deferred income tax credit |  | 21 |  |  | 12 |  |  | 14 |
Tax expense |  | $ | 185 |  |  | $ | 142 |  |  | $ | 339 |
For the year ended December 31, 2017, the impact of the TCJA was a $148 million increase in deferred income tax expense at CMS Energy, including Consumers, and a $33 million increase in deferred income tax expense at Consumers. The TCJA had no impact on current income tax expense in 2017. Presented in the following table are the principal components of deferred income tax assets (liabilities) recognized:
In Millions |
December 31 | 2019 |  | 2018 |
CMS Energy, including Consumers |  |  |  |
Deferred income tax assets |  |  |  |
Tax loss and credit carryforwards |  | $ | 239 |  |  | $ | 385 |
Net regulatory tax liability |  | 385 |  |  | 395 |
Reserves and accruals |  | 43 |  |  | 39 |
Total deferred income tax assets |  | $ | 667 |  |  | $ | 819 |
Valuation allowance |  | (2 | ) |  | (8 | )
Total deferred income tax assets, net of valuation allowance |  | $ | 665 |  |  | $ | 811 |
Deferred income tax liabilities |  |  |  |
Plant, property, and equipment |  | $ | (2,033 | ) |  | $ | (1,955 | )
Employee benefits |  | (172 | ) |  | (165 | )
Securitized costs |  | (59 | ) |  | (65 | )
Gas inventory |  | (32 | ) |  | (35 | )
Other |  | (24 | ) |  | (78 | )
Total deferred income tax liabilities |  | $ | (2,320 | ) |  | $ | (2,298 | )
Total net deferred income tax liabilities |  | $ | (1,655 | ) |  | $ | (1,487 | )
Consumers |  |  |  |
Deferred income tax assets |  |  |  |
Net regulatory tax liability |  | $ | 385 |  |  | $ | 395 |
Tax loss and credit carryforwards |  | 20 |  |  | 64 |
Reserves and accruals |  | 24 |  |  | 21 |
Total deferred income tax assets |  | $ | 429 |  |  | $ | 480 |
Deferred income tax liabilities |  |  |  |
Plant, property, and equipment |  | $ | (1,995 | ) |  | $ | (1,943 | )
Employee benefits |  | (178 | ) |  | (172 | )
Securitized costs |  | (59 | ) |  | (65 | )
Gas inventory |  | (32 | ) |  | (35 | )
Other |  | (29 | ) |  | (74 | )
Total deferred income tax liabilities |  | $ | (2,293 | ) |  | $ | (2,289 | )
Total net deferred income tax liabilities |  | $ | (1,864 | ) |  | $ | (1,809 | )
Deferred tax assets and liabilities are recognized for the estimated future tax effect of temporary differences between the tax basis of assets or liabilities and the reported amounts on CMS Energy’s and Consumers’ consolidated financial statements. Presented in the following table are the tax loss and credit carryforwards at December 31, 2019:
In Millions
| Gross Amount |  | Tax Attribute |  | Expiration
CMS Energy, including Consumers |  |  |  |  |
Local net operating loss carryforwards |  | $ | 389 |  |  | $ | 4 |  | 2023 – 2036
General business credits |  | 206 |  |  | 206 |  | 2026 – 2039
Alternative minimum tax credits |  | 29 |  |  | 29 |  | Not applicable
Total tax attributes |  |  |  | $ | 239 |  |
Consumers |  |  |  |  |
General business credits |  | $ | 20 |  |  | $ | 20 |  | 2027 – 2039
Total tax attributes |  |  |  | $ | 20 |  |
CMS Energy has provided a valuation allowance of $2 million for the local tax loss carryforward. The TCJA repealed the corporate alternative minimum tax and requires companies to recover (through offsets of regular tax and through cash refunds) all alternative minimum tax credits over the four-year period ending in 2021. Therefore, for the year ended December 31, 2019, CMS Energy reclassified $31 million of alternative minimum tax credits to a current receivable. CMS Energy and Consumers expect to utilize fully their tax loss and credit carryforwards for which no valuation allowance has been provided. It is reasonably possible that further adjustments will be made to the valuation allowances within one year. Presented in the following table is a reconciliation of the beginning and ending amount of uncertain tax benefits:
In Millions |
Years Ended December 31 | 2019 |  | 2018 |  | 2017 |
CMS Energy, including Consumers |  |  |  |  |  |
Balance at beginning of period |  | $ | 19 |  |  | $ | 14 |  |  | $ | 5 |
Additions for current-year tax positions |  | 1 |  |  | 1 |  |  | 10 |
Additions for prior-year tax positions |  | 3 |  |  | 4 |  |  | — |
Reductions for prior-year tax positions |  | — |  |  | — |  |  | (1 | )
Balance at end of period |  | $ | 23 |  |  | $ | 19 |  |  | $ | 14 |
Consumers |  |  |  |  |  |
Balance at beginning of period |  | $ | 28 |  |  | $ | 21 |  |  | $ | 5 |
Additions for current-year tax positions |  | 1 |  |  | 2 |  |  | 17 |
Additions for prior-year tax positions |  | 5 |  |  | 5 |  |  | — |
Reductions for prior-year tax positions |  | — |  |  | — |  |  | (1 | )
Balance at end of period |  | $ | 34 |  |  | $ | 28 |  |  | $ | 21 |
If recognized, all of these uncertain tax benefits would affect CMS Energy’s and Consumers’ annual effective tax rates in future years. CMS Energy and Consumers recognize accrued interest and penalties, where applicable, as part of income tax expense. CMS Energy, including Consumers, recognized no interest or penalties for the years ended December 31, 2019, 2018, or 2017. The amount of income taxes paid is subject to ongoing audits by federal, state, local, and foreign tax authorities, which can result in proposed assessments. CMS Energy’s federal income tax returns for 2016 and subsequent years remain subject to examination by the IRS. CMS Energy’s Michigan Corporate Income Tax returns for 2013 and subsequent years remain subject to examination by the State of Michigan. CMS Energy’s and Consumers’ estimate of the potential outcome for any uncertain tax issue is highly judgmental. CMS Energy and Consumers believe that their accrued tax liabilities at December 31, 2019 were adequate for all years.
Consumers Energy Company |
Income Taxes [Line Items] |
Income Taxes | Income Taxes CMS Energy and its subsidiaries file a consolidated U.S. federal income tax return as well as a Michigan Corporate Income Tax return for the unitary business group and various other state unitary group combined income tax returns. Income taxes are allocated based on each company’s separate taxable income in accordance with the CMS Energy tax sharing agreement. In December 2017, the TCJA was enacted, which changed existing federal tax law and included numerous provisions that affect businesses, with the primary impact being a reduction of the corporate tax rate from 35 percent to 21 percent. Presented in the following table is the difference between actual income tax expense on continuing operations and income tax expense computed by applying the statutory U.S. federal income tax rate:
In Millions, Except Tax Rate |
Years Ended December 31 | 2019 |  | 2018 |  | 2017 |
CMS Energy, including Consumers |  |  |  |  |  |
Income from continuing operations before income taxes |  | $ | 829 |  |  | $ | 774 |  |  | $ | 886 |
Income tax expense at statutory rate |  | 174 |  |  | 163 |  |  | 310 |
Increase (decrease) in income taxes from: |  |  |  |  |  |
State and local income taxes, net of federal effect 1 |  | 48 |  |  | 46 |  |  | 26 |
TCJA excess deferred taxes 2 |  | (31 | ) |  | (26 | ) |  | — |
Production tax credits |  | (20 | ) |  | (14 | ) |  | (8 | )
Accelerated flow-through of regulatory tax benefits 3 |  | (13 | ) |  | (39 | ) |  | (39 | )
Research and development tax credits, net 4 |  | (2 | ) |  | (11 | ) |  | (1 | )
Impact of the TCJA 5 |  | — |  |  | (4 | ) |  | 148 |
Other, net |  | (9 | ) |  | — |  |  | (12 | )
Income tax expense |  | $ | 147 |  |  | $ | 115 |  |  | $ | 424 |
Effective tax rate |  | 17.7 | % |  | 14.9 | % |  | 47.9 | %
Consumers |  |  |  |  |  |
Income from continuing operations before income taxes |  | $ | 928 |  |  | $ | 847 |  |  | $ | 971 |
Income tax expense at statutory rate |  | 195 |  |  | 178 |  |  | 340 |
Increase (decrease) in income taxes from: |  |  |  |  |  |
State and local income taxes, net of federal effect 1 |  | 53 |  |  | 51 |  |  | 30 |
TCJA excess deferred taxes 2 |  | (31 | ) |  | (26 | ) |  | — |
Accelerated flow-through of regulatory tax benefits 3 |  | (13 | ) |  | (39 | ) |  | (39 | )
Production tax credits |  | (12 | ) |  | (12 | ) |  | (8 | )
Research and development tax credits, net 4 |  | (2 | ) |  | (11 | ) |  | (1 | )
Impact of the TCJA 5 |  | — |  |  | 1 |  |  | 33 |
Other, net |  | (5 | ) |  | — |  |  | (16 | )
Income tax expense |  | $ | 185 |  |  | $ | 142 |  |  | $ | 339 |
Effective tax rate |  | 19.9 | % |  | 16.8 | % |  | 34.9 | %
1 | In 2017, CMS Energy completed the evaluation of its methodology for the state apportionment of Consumers’ electricity sales to MISO, taking into account recent state tax law developments in the electric utility sector. To recognize the anticipated refund and the impact of the expected lower effective tax rate on their deferred state tax liabilities, CMS Energy, including Consumers, recorded a $14 million income tax benefit in 2017. These tax benefits were net of reserves for uncertain tax positions and primarily
attributable to Consumers. In 2018, CMS Energy amended its 2013 Michigan Corporate Income Tax return and submitted a refund claim for taxes previously paid. The refund claim was denied by the State of Michigan. In 2019, CMS Energy received an unfavorable informal conference decision and filed a petition with the Michigan Tax Tribunal. A trial is anticipated in 2020. CMS Energy’s uncertain tax position on this matter remains unchanged.
2 | In December 2017, Consumers remeasured its deferred tax assets and liabilities at the new federal tax rate enacted by the TCJA and recorded a net $1.6 billion regulatory liability. As a result of an order received in September 2019, Consumers began refunding these excess deferred taxes to customers. For additional details on the order received, see Note 3, Regulatory Matters.
3 | In 2013, the MPSC issued an order authorizing Consumers to accelerate the flow-through to electric and gas customers of certain income tax benefits associated primarily with the cost of removal of plant placed in service before 1993. Consumers implemented this regulatory treatment beginning in 2014, with the electric portion ending in 2018 and the gas portion continuing through 2025.
4 | In March 2018, Consumers finalized a study of research and development tax credits for the tax years 2012 through 2016. As a result, Consumers recognized an $8 million increase in the credit, net of reserves for uncertain tax positions, at that time.
5 | In December 2017, CMS Energy and Consumers recorded a reasonable estimate to measure and account for the impact of the TCJA. In December 2018, CMS Energy recorded a true-up of their estimate and eliminated the $9 million valuation allowance on the sequestration of alternative minimum tax credits.
Presented in the following table are the significant components of income tax expense on continuing operations:
In Millions |
Years Ended December 31 | 2019 |  | 2018 |  | 2017 |
CMS Energy, including Consumers |  |  |  |  |  |
Current income taxes |  |  |  |  |  |
Federal |  | $ | (31 | ) |  | $ | (67 | ) |  | $ | — |
State and local |  | 28 |  |  | — |  |  | 6 |
|  | $ | (3 | ) |  | $ | (67 | ) |  | $ | 6 |
Deferred income taxes |  |  |  |  |  |
Federal |  | $ | 97 |  |  | $ | 112 |  |  | $ | 368 |
State and local |  | 32 |  |  | 58 |  |  | 36 |
|  | $ | 129 |  |  | $ | 170 |  |  | $ | 404 |
Deferred income tax credit |  | 21 |  |  | 12 |  |  | 14 |
Tax expense |  | $ | 147 |  |  | $ | 115 |  |  | $ | 424 |
Consumers |  |  |  |  |  |
Current income taxes |  |  |  |  |  |
Federal |  | $ | 107 |  |  | $ | 6 |  |  | $ | 159 |
State and local |  | 41 |  |  | 13 |  |  | 17 |
|  | $ | 148 |  |  | $ | 19 |  |  | $ | 176 |
Deferred income taxes |  |  |  |  |  |
Federal |  | $ | (10 | ) |  | $ | 60 |  |  | $ | 120 |
State and local |  | 26 |  |  | 51 |  |  | 29 |
|  | $ | 16 |  |  | $ | 111 |  |  | $ | 149 |
Deferred income tax credit |  | 21 |  |  | 12 |  |  | 14 |
Tax expense |  | $ | 185 |  |  | $ | 142 |  |  | $ | 339 |
For the year ended December 31, 2017, the impact of the TCJA was a $148 million increase in deferred income tax expense at CMS Energy, including Consumers, and a $33 million increase in deferred income tax expense at Consumers. The TCJA had no impact on current income tax expense in 2017. Presented in the following table are the principal components of deferred income tax assets (liabilities) recognized:
In Millions |
December 31 | 2019 |  | 2018 |
CMS Energy, including Consumers |  |  |  |
Deferred income tax assets |  |  |  |
Tax loss and credit carryforwards |  | $ | 239 |  |  | $ | 385 |
Net regulatory tax liability |  | 385 |  |  | 395 |
Reserves and accruals |  | 43 |  |  | 39 |
Total deferred income tax assets |  | $ | 667 |  |  | $ | 819 |
Valuation allowance |  | (2 | ) |  | (8 | )
Total deferred income tax assets, net of valuation allowance |  | $ | 665 |  |  | $ | 811 |
Deferred income tax liabilities |  |  |  |
Plant, property, and equipment |  | $ | (2,033 | ) |  | $ | (1,955 | )
Employee benefits |  | (172 | ) |  | (165 | )
Securitized costs |  | (59 | ) |  | (65 | )
Gas inventory |  | (32 | ) |  | (35 | )
Other |  | (24 | ) |  | (78 | )
Total deferred income tax liabilities |  | $ | (2,320 | ) |  | $ | (2,298 | )
Total net deferred income tax liabilities |  | $ | (1,655 | ) |  | $ | (1,487 | )
Consumers |  |  |  |
Deferred income tax assets |  |  |  |
Net regulatory tax liability |  | $ | 385 |  |  | $ | 395 |
Tax loss and credit carryforwards |  | 20 |  |  | 64 |
Reserves and accruals |  | 24 |  |  | 21 |
Total deferred income tax assets |  | $ | 429 |  |  | $ | 480 |
Deferred income tax liabilities |  |  |  |
Plant, property, and equipment |  | $ | (1,995 | ) |  | $ | (1,943 | )
Employee benefits |  | (178 | ) |  | (172 | )
Securitized costs |  | (59 | ) |  | (65 | )
Gas inventory |  | (32 | ) |  | (35 | )
Other |  | (29 | ) |  | (74 | )
Total deferred income tax liabilities |  | $ | (2,293 | ) |  | $ | (2,289 | )
Total net deferred income tax liabilities |  | $ | (1,864 | ) |  | $ | (1,809 | )
Deferred tax assets and liabilities are recognized for the estimated future tax effect of temporary differences between the tax basis of assets or liabilities and the reported amounts on CMS Energy’s and Consumers’ consolidated financial statements. Presented in the following table are the tax loss and credit carryforwards at December 31, 2019:
In Millions
| Gross Amount |  | Tax Attribute |  | Expiration
CMS Energy, including Consumers |  |  |  |  |
Local net operating loss carryforwards |  | $ | 389 |  |  | $ | 4 |  | 2023 – 2036
General business credits |  | 206 |  |  | 206 |  | 2026 – 2039
Alternative minimum tax credits |  | 29 |  |  | 29 |  | Not applicable
Total tax attributes |  |  |  | $ | 239 |  |
Consumers |  |  |  |  |
General business credits |  | $ | 20 |  |  | $ | 20 |  | 2027 – 2039
Total tax attributes |  |  |  | $ | 20 |  |
CMS Energy has provided a valuation allowance of $2 million for the local tax loss carryforward. The TCJA repealed the corporate alternative minimum tax and requires companies to recover (through offsets of regular tax and through cash refunds) all alternative minimum tax credits over the four-year period ending in 2021. Therefore, for the year ended December 31, 2019, CMS Energy reclassified $31 million of alternative minimum tax credits to a current receivable. CMS Energy and Consumers expect to utilize fully their tax loss and credit carryforwards for which no valuation allowance has been provided. It is reasonably possible that further adjustments will be made to the valuation allowances within one year. Presented in the following table is a reconciliation of the beginning and ending amount of uncertain tax benefits:
In Millions |
Years Ended December 31 | 2019 |  | 2018 |  | 2017 |
CMS Energy, including Consumers |  |  |  |  |  |
Balance at beginning of period |  | $ | 19 |  |  | $ | 14 |  |  | $ | 5 |
Additions for current-year tax positions |  | 1 |  |  | 1 |  |  | 10 |
Additions for prior-year tax positions |  | 3 |  |  | 4 |  |  | — |
Reductions for prior-year tax positions |  | — |  |  | — |  |  | (1 | )
Balance at end of period |  | $ | 23 |  |  | $ | 19 |  |  | $ | 14 |
Consumers |  |  |  |  |  |
Balance at beginning of period |  | $ | 28 |  |  | $ | 21 |  |  | $ | 5 |
Additions for current-year tax positions |  | 1 |  |  | 2 |  |  | 17 |
Additions for prior-year tax positions |  | 5 |  |  | 5 |  |  | — |
Reductions for prior-year tax positions |  | — |  |  | — |  |  | (1 | )
Balance at end of period |  | $ | 34 |  |  | $ | 28 |  |  | $ | 21 |
If recognized, all of these uncertain tax benefits would affect CMS Energy’s and Consumers’ annual effective tax rates in future years. CMS Energy and Consumers recognize accrued interest and penalties, where applicable, as part of income tax expense. CMS Energy, including Consumers, recognized no interest or penalties for the years ended December 31, 2019, 2018, or 2017. The amount of income taxes paid is subject to ongoing audits by federal, state, local, and foreign tax authorities, which can result in proposed assessments. CMS Energy’s federal income tax returns for 2016 and subsequent years remain subject to examination by the IRS. CMS Energy’s Michigan Corporate Income Tax returns for 2013 and subsequent years remain subject to examination by the State of Michigan. CMS Energy’s and Consumers’ estimate of the potential outcome for any uncertain tax issue is highly judgmental. CMS Energy and Consumers believe that their accrued tax liabilities at December 31, 2019 were adequate for all years.

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