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OPINION
NIMS, Judge: Respondent determined a Federal income tax
deficiency for petitioner’s 1993 taxable year in the amount of
$1,712,070. After concessions, the issue for decision is whether
petitioner, an accrual method taxpayer, may deduct costs expended
for licenses, permits, fees, and insurance in the year paid
rather than amortizing such costs over the taxable years to which
they relate.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
This case was submitted fully stipulated, and the facts are
so found. The stipulations filed by the parties, with
accompanying exhibits, are incorporated herein by this reference.
Background
USFreightways Corporation is, and was at the time of filing
the petition in this case, a Delaware corporation with a
principal place of business in Rosemont, Illinois. USFreightways
and its subsidiaries (hereinafter collectively petitioner) are
engaged in the business of transporting freight for hire by
trucks throughout the continental United States.
Incident to its trucking business, petitioner is required by
State and local government authorities to make expenditures for
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Last modified: May 25, 2011