Tax Accounting

Tax accounting
1.461-2(c)(1)
1.461-4(d)(1) through (6)
1.461-4(e)
1.461-4(g)(1) through (7)
1.461-5 (a) through (c)

Garber Abbey B [[e-mail]]

Monday, February 04, 2013 11:30 PM
Here are a few regulations
Treas. Reg. sec. 1.461-1(a)(2)(i)
Reg. sec. 1.461-1(a)(2)(ii)
Reg. sec. 1.461-1(a)(3)
Reg. sec. 1.461-1(c)
We’ll work through these and more Thursday.
Initial assignments for February 7:

I.R.C. section 461 Look at Treas. Reg. Section 1.461-0 for now to get a handle on what we are doing.
I will specify parts of regs 1.461-1, 1.461-2, 1.461-4, 1.461-5 to look at later Hughes Properties, Inc., 476 U.S. 593 (1986)
Mooney Aircraft, 420 F.2d 400 (5th. Cir. 1969)
General Dynamics, 481 U.S. 239 (1987) Gertzman chapter 4, pp. 64-133. Abbey B. Garber

107 S.Ct. 1732
Supreme Court of the United States
UNITED STATES, Petitioner
v.
GENERAL DYNAMICS CORP., et al.
No. 85-1385.
Argued Jan. 13, 1987.Decided April 22, 1987.
Accrual basis taxpayer sued for income tax refund, alleging that it was entitled to deduct, as a business expense, an estimate of its obligation to pay for employee medical care during the final quarter of the taxable year. The Claims Court, Robert M.M. Seto, J., 6 Cl.Ct. 250, found for taxpayer and Government appealed. The Court of Appeals, 773 F.2d 1224, affirmed. After granting certiorari, the Supreme Court, Justice Marshall, held that under the “all events” test, accrual basis taxpayer which provided medical benefits to its employees could not deduct at close of taxable year an estimate of its obligation to pay for such medical care during the final quarter of the year, with regard to claims which had not yet been reported to taxpayer.
Reversed.
Justice O 'Connor filed a dissenting opinion in which Justices Blackmun and Stevens joined.
West Headnotes (5)Expand West Headnotes
**1733 Syllabus*
*239 Under the “all events” test, as embodied in Treasury Regulations, an

Citations: 106 S.Ct. 2092 Supreme Court of the United States Argued April 23, 1986.Decided June 3, 1986. Held: Respondent was entitled to claim the deductions in question. Pp. 2095-2100. (a) The “all events” test prescribed by the Treasury Regulations requires that before an expense can be regarded as “incurred” for federal income tax purposes, a liability must be fixed and absolute. Pp. 2096-2097. (d) Nothing in the record indicates that respondent used its progressive slot machines for tax-avoidance purposes. Pp. 2098-2099. (e) The potential that a casino operator might go out of business, or surrender or lose its license, or go into bankruptcy, with the result that the progressive jackpot would never be paid, does not prevent accrual of the expense. P. 2099. 760 F.2d 1292 (Fed.Cir.1986), affirmed. Because of the clear conflict between the two Circuits, we granted certiorari. 474 U.S. 1004, 106 S.Ct. 522, 88 L.Ed.2d 455 (1985).