- 9 - years must be added back. The purpose of these adjustments is to find the amount by which income has been allowed to accumulate beyond the needs of the business for a particular tax year. Respondent’s interpretation of the regulatory phrase accomplishes that end. Petitioner’s interpretation, on the other hand, addresses the question of future tax liability.8 Under established tax accounting principles for accrual, a liability is incurred and/or taken into account in the year in which all the events have occurred that establish the fact of the liability. See sec. 1.461-1(a)(2), Income Tax Regs. All the events have occurred when the amount of the liability can be determined with reasonable accuracy and economic performance has occurred with respect to the liability. Id. All of the events have not occurred with respect to petitioner’s tax liability on future years’ installment sale income. Accordingly, petitioner is not entitled to deduct tax on post-1995 installment sale income from taxable income in arriving at accumulated taxable income for 1995. 8 To the extent that petitioner receives installment income in future years, the tax and income would be matched in the same taxable year and have a direct bearing on whether that income was allowed to accumulate beyond its needs for that future year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011