- 16 - left AIM in 1996 that Scott considered the $14,900 to be compensation. These facts show that the loan became worthless in 1996. Respondent points out that petitioner did not sue Scott. However, to prove that a debt is worthless, a taxpayer is not required to sue to obtain repayment if, as here, the circumstances indicate that a lawsuit to enforce payment would probably not result in satisfaction of a judgment. Exxon Corp. v. United States, 785 F.2d 277, 279 (Fed. Cir. 1986); sec. 1.166- 2(a) and (b), Income Tax Regs. We conclude that AIM may deduct the $14,900 as a bad debt in 1996. C. Whether AIM Had Cost of Goods Sold of $103,415 in 1994 Petitioners contend that AIM’s cost of goods sold for 1994 was $103,415. Respondent contends that it was $85,883. The difference of $17,532 relates to labor and material expenses AIM incurred for work it did for Morton International in 1994 and 1995. AIM paid those expenses in December 1994 and, in January 1995, completed the job and billed Morton International. Deductions under the accrual method of accounting are allowable for the taxable year in which all events have occurred that establish the fact of the liability, the amount of the liability can be determined with reasonable accuracy, and economic performance has occurred with respect to the liability.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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