- 17 - tax deficiencies were assessed by respondent (namely, in 1981, for the interest relating to the 1972 and 1973 tax deficiencies; in 1985, for the interest relating to the 1974, 1975, and 1976 tax deficiencies; and in 1989, for the interest relating to the 1977 and 1978 tax deficiencies). In 1989 and 1990 in the petitions filed in these cases, petitioners made the claim that the total statutory interest that related to Exxon’s agreed income tax deficiencies for 1972 through 1978 should be accrued not in and for the year the audits for those years were concluded and in which the Form 870 agreements were entered into or the year in which the assessments occurred (namely, 1981, 1985, and 1989), but that the interest should relate back to the years 1973 through 1989 and should accrue ratably in each year to which the interest relates. OPINION Under section 461(a), a deduction is to be allowed in the proper taxable year under the method of accounting used in computing a taxpayer’s income. Under the all-events test of the accrual method of accounting, a liability expense accrues in the year in which all the events have occurred which establish the fact of liability for the expense and in which the amount of the liability can be determined with reasonable accuracy. See United States v.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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