13 determined the fact of the liability and (b) the amount of the liability could be determined with reasonable accuracy. United States v. Anderson, 269 U.S. 422, 437-438, 441 (1926). DEFRA sec. 91(a), 98 Stat. 606, provided that the all events test is not met before economic performance occurs. Sec. 461(h)(1). In the case of liability to pay a person who provides goods or services to the taxpayer, economic performance occurs as that person provides the goods or services to the taxpayer. Sec. 461(h)(2)(A)(i). In the legislative history accompanying enactment of the economic performance rules, Congress described the pre-DEFRA law, gave an overview of the House bill, discussed the economic performance rules added by DEFRA, and described the predecessor of the specified liability loss rule. The conference report for DEFRA states in pertinent part: G. Accounting Changes 1. Premature accruals * * * * * * * Economic Performance * * * * * * * Net operating loss carrybacks The House bill provides a 10-year carryback for net operating losses attributable to certain liabilities deferred under these provisions. The bill also provides a special carryback rule for losses incurred in connection with the decommissioning of a nuclear power plant. SuchPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011