General Communication Co. v. Commissioner
United States Tax Court
Held, petitioner's alleged liability to R.C.A. under a patent-licensing agreement was neither uncontested nor sufficiently fixed as of the end of the taxable year (Sept. 30, 1954) to justify accrual thereof.
1Opinion of the Court
OriNION.
Raum, Judge:
We have carefully considered the testimony and documentary evidence of record and have come to the conclusion that the accrued royalty liability in question was not sufficiently fixed or definite as of September 30, 1954, to warrant deduction at that time. The requirements for the deductibility of accrued liabilities have been variously stated. In Dixie Pine Products Co. v. Commissioner, 320 U.S. 516, 519, it was regarded as settled law “that in order to truly reflect the income of a given year, all the events must occur in that year which fix the amount and the fact of…
2Cases cited5 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Producers' Fuel Co. v. CommissionerUnited States Board of Tax Appeals · 1924
- Bump Confectionery Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- New Process Cork Co. v. CommissionerUnited States Board of Tax Appeals · 1926
3Cited by8 opinions
- Phillips Petroleum Co. v. CommissionerUnited States Tax Court · 1991
- Boecking v. CommissionerUnited States Tax Court · 1993
- General Communication Co. v. CommissionerUnited States Tax Court · 1960
- Hitachi Sales Corp. v. CommissionerUnited States Tax Court · 1992
- Reid v. CommissionerUnited States Tax Court · 1981
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