Restore, Inc. - Page 16

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          contingency which may never be met.  Because petitioner, under              
          the control of Matrix, may never be deemed to have met its goals            
          of a certain profit or cash-flow level or may in any given year             
          not be profitable at all, petitioner has taken deductions for               
          expenditures which might never occur.  See United States v.                 
          Hughes Properties, Inc., 476 U.S. at 601-603; Putoma Corp. v.               
          Commissioner, 601 F.2d at 739-740; Mooney Aircraft, Inc. v.                 
          United States, supra at 406; Burlington-Rock Island R.R. v.                 
          United States, supra at 818-820.  We hold that the all events               
          test was not satisfied.                                                     
               The second issue for determination is whether petitioner may           
          deduct interest accruals allegedly owed to its foreign parent on            
          the accrued but unpaid royalties.  Petitioner has accrued                   
          interest on the royalties payable to Matrix, and we have found              
          that the payment of those royalties is contingent.  It follows              
          that the accrued interest may not be regarded as an accrued                 
          expense until the years in which the contingency is satisfied and           
          the obligation to pay the royalties becomes fixed and absolute.             
          Burlington-Rock Island R.R. v. United States, supra at 819                  
          (citing Pierce Estates, Inc., v. Commissioner, 195 F.2d 475, 477-           
          478 (3d Cir. 1952), revg. 16 T.C. 1020 (1951)); see also Fox v.             
          Commissioner, 874 F.2d 560, 563 (8th Cir. 1989), affg. T.C. Memo.           
          1987-209; Putoma Corp. v. Commissioner, 601 F.2d at 740.                    
               Finally, respondent determined that petitioner is liable for           
          accuracy-related penalties under section 6662.  Section 6662(a)             




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