Metro Leasing and Development Corporation, East Bay Chevrolet Company, a Corporation - Page 9




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            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.                                







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