- 18 - In a letter dated May 9, 1996, the Nortons requested reimbursement for the following expenses from the controlled savings account: Vendor Description Amount GeoCHEM, Inc. Pit liner $1,987.50 Weld-Air Angle iron and welding rod 359.00 Brad Zweifel Co. Soil removal 414.00 Knapp Enterprises Soil removal 414.00 Total 3,174.50 The requested amount was released to the Nortons. They paid off the NBA loan in 1999. At the time the loan was satisfied, the controlled savings account had a balance of $6,000 to $8,000; this amount was released to the Nortons. Upon the advice of Mrs. Crockett, the Nortons offset their 1993 Schedule E income with a $15,000 deduction for environmental cleanup expenses. Respondent disallowed the claimed deduction. Before a taxpayer is allowed a current deduction, a claimed expense must be paid or incurred. The Nortons are cash method taxpayers, and under such method expenses are deductible or capitalized only after such expenses have been actually paid. See sec. 1.461-1(a)(1), Income Tax Regs. The Nortons did not incur or pay any environmental cleanup expenses in 1993.2 Rather, they merely made a deposit into a controlled savings account. (The purpose of the controlled account 2 Because the Nortons did not make any expenditures for environmental cleanup costs in 1993, the question of whether such costs would be currently deductible is moot.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011