- 22 - adjustment were not treated as making the tax adjustment contested and nonaccruable. H.E. Fletcher Co. v. Commissioner, a Memorandum Opinion of this Court dated Oct. 26, 1951, involved a taxpayer’s attempt to accrue interest relating to tax adjustments in the year in which the interest was paid, not for years to which the interest related. The case involved no evidence that the tax adjustments were contested or other than fixed and definite. The Court did not allow the accrual basis taxpayer to accrue the interest in the later year in which the interest was paid. As we understand the above authorities, situations which would allow the accrual of interest relating to tax audit adjustments for the years to which the interest relates generally are distinguishable from situations such as those involved herein (namely, situations where facts relating to the tax audit adjustments and the amounts thereof are, for a number of years, indefinite, where the adjustments are eventually developed based largely on information available to both taxpayers’ and respondent’s representatives only over the course of years after the filing of the tax returns, where negotiations occur with regard to the nature and character of the underlying transactions giving rise to the tax adjustments, and where agreements with regard to the tax adjustments are reached through such negotiations years after the filing of the tax returns to whichPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011