the utility had realized its fair share of the savings resulting from that return” if certain conditions are met. PURA § 36.060 (emphasis added). This mandatory language requires the Commission to compute a CTSA in order to pass along to ratepayers not only actually realized tax savings achieved via a consolidated return but even unrealized or hypothetical tax savings that have been forgone by a utility and its affiliates in unreasonably choosing not to consolidate returns when they are able to do so. The legislative intention expressed in section 36.060 requires that available tax savings inure to ratepayers. See Reliant Energy, 153 S.W.3d at 199 (CTSA is performed for ratepayers’ benefit); see also Public Util. Comm’n v. Houston Lighting & Power Co., 748 S.W.2d 439, 442 (Tex.1987) (<HOLDING>). In other words, section 36.060 requires that
holding that where no witness testified in support of a method of calculating consolidated tax savings by determining todays value of past tax savings commissions use of method was improper holding that tax savings generated by utilitys expense writeoff should inure to ratepayers holding that although the attorney successfully argued for a reduction in the tax assessment of his clients property producing a measurable saving of taxes for three tax years the savings were not proceeds subject to a lien within the meaning of new yorks attorneys lien statute holding that state legislature should determine whether to cure discriminatory tax by enforcing tax as to all or forgiving tax in its entirety holding where plaintiffs transfer between employee benefit plans generated tax liability that fact that plaintiffs may have performed the transfer pursuant to advice from defendants does not convert plaintiffs tax liability into consequential damages