- 13 - and revd. in part on other grounds 184 F.3d 786 (8th Cir. 1999); Higginbotham-Bailey-Logan Co. v. Commissioner, 8 B.T.A. 566 (1927). For instance, in Johnson v. Commissioner, supra, a taxpayer employing the accrual method purchased insurance policies covering periods of 1 to 7 years. Given this scenario, the Court made no attempt to ascertain which of the policies, such as those covering only 1 year, would expire within the following taxable year. Instead, the Court ruled that “to the extent that part of any Premium was allocable to coverage for subsequent years, it must be capitalized and amortized by deductions in those years.” Id. at 488. Likewise, in Higginbotham-Bailey-Logan Co. v. Commissioner, supra, the Court disallowed a deduction for prepaid insurance taken by an accrual basis taxpayer without inquiring into whether the policy might terminate within the next year. The Court resolved the issue by stating: “The adjustment made by the Commissioner appears to be in accordance with the method of accounting employed by the petitioner and appears further to be such that petitioner’s net income is more nearly correctly reflected than on the basis used in the return.” Id. at 577. Hence, beginning as early as 1927 and followed as recently as 1997, reported cases have indicated that an accrual basisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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