Fleetboston Financial Corp. v. United States

OPINION

ALLEGRA, Judge.

*178“Neither a borrower nor lender be ...”1

Under the Internal Revenue Code, it is difficult for a large corporate taxpayer to follow the sage advice given by Polonius to his son, Laertes. That is, in part, because, although the income tax system is often identified with its annual accounting principle, various statutory exceptions thereto allow certain deductions and tax payments to be shifted from one tax year to another, causing the tax accounts of many taxpayers to vacillate between debit and credit status.

One such provision, section 6402(b) of the Internal Revenue Code,…