| United States. Tax Court - 1974 - 862 pages
...using the gross-profit percentage from the Derby's own books and records which reflect such accrual. "Under an accrual method of accounting, an expense...thereof can be determined with reasonable accuracy. * * * Where a deduction is properly accrued on the basis of a computation made with reasonable accuracy... | |
| United States. Tax Court - 1992 - 764 pages
...payments were not properly accruable. 'Sec. 1.4€ll(aX2), Income Tax Regs, provides that "Under the accrual method of accounting, an expense is deductible...thereof can be determined with reasonable accuracy." See also Rev. Rul. 61-127, 1961-2 CB 36. for payments of compensation; however, if compensation is... | |
| United States. Tax Court - 1973 - 1208 pages
...compensation to amounts actually paid. Section 1.461-1 (a) (2) , Income Tax Regs., states : Under ail accrual method of accounting, an expense is deductible...thereof can be determined with reasonable accuracy. * * * It is respondent's position that adherence to the all-events rule precludes petitioner from accruing... | |
| United States. Tax Court - 1989 - 1186 pages
...which paid." Sec. 1.461-l(a)(l), Income Tax Regs. Under the accrual method of accounting, interest is deductible "for the taxable year in which all the...thereof can be determined with reasonable accuracy." Sec. 1.461l(a)(2), Income Tax Regs. See sec. 1.446-l(c)(l)(ii), Income Tax Regs.; Lay v. Commissioner,... | |
| United States. Tax Court - 1991 - 712 pages
...regulations further provide that a taxpayer using an accrual method of accounting may deduct an expense for the taxable year in which all the events have...thereof can be determined with reasonable accuracy. Sec. 1.461-l(a)(2), Income Tax Regs. While no accrual shall be made where all the events which fix... | |
| United States. Tax Court - 1985 - 1410 pages
...amortization deductions from such time. Under the accrual method of accounting, an expense is deductible in the taxable year in which "all the events have occurred...thereof can be determined with reasonable accuracy." Sec. 1.461-l(a)(2), Income Tax Regs.; see United States v. Anderson, 269 US 422, 442 (1926). The petitioners... | |
| United States. Tax Court - 1988 - 1416 pages
...method of accounting. Sec. 461(a). The Goodbody partnership was on the accrual method of accounting. Under an accrual method of accounting, an expense...the events have occurred which determine the fact of liability and the amount thereof can be determined with reasonable accuracy. Sec. 1.461-l(a)(2), Income... | |
| United States. Tax Court - 1984 - 1104 pages
...reasons set out below. A taxpayer using the accrual method of accounting may deduct expenses only when "all the events have occurred which determine the...thereof can be determined with reasonable accuracy." Sec. 1.461-l(a)(2), Income Tax Regs.; United States v. Anderson, supra. State income taxes ordinarily... | |
| United States. Tax Court - 1984 - 1120 pages
...1930). An accrual method taxpayer may deduct a loss even though he has not paid it, so long as all events have occurred which determine the fact of the...thereof can be determined with reasonable accuracy. Sec. 1.461-l(a)(2), Income Tax Regs.; CF Mueller Co. v. Commissioner, 40 BTA 195, 203 (1939). Losses... | |
| United States. Tax Court - 1975 - 1220 pages
...in the prior year. See also sec. 1.404(a)-l(c), Income Tax Regs. It has long been established that under an accrual method of accounting an expense is deductible for the taxable year in which all events have occurred which determine the fact of liability and the amount thereof can be determined... | |
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