Legal Opinion

VECO Corp. & Subsidiaries v. Commissioner

United States Tax Court

Decided November 20, 2013No. Docket No. 24918-10PublishedCited by 2 opinions

On its Federal income tax return for the taxable year ending Mar. 31, 2005 (TYE 2005), P, an accrual method taxpayer, implemented a proposed change in accounting method and in so doing accelerated deductions for parts of certain liabilities attributable to periods after the close of P's TYE 2005. R rejected P's proposed change in accounting method and denied P's claimed accelerated deductions.

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On its Federal income tax return for the taxable year ending Mar. 31, 2005 (TYE 2005), P, an accrual method taxpayer, implemented a proposed change in accounting method and in so doing accelerated deductions for parts of certain liabilities attributable to periods after the close of P's TYE 2005. R rejected P's proposed change in accounting method and denied P's claimed accelerated deductions. P claims that it was entitled to accelerate the deductions under the "all events" test of I.R.C. sec. 461 and/or the recurring item exception to the economic performance rules of I.R.C. sec. 461(h)(3).…

1Opinion of the Court

OPINION

Marvel, Judge:

On its Federal income tax return for the taxable year ending (TYE) March 31, 2005, VECO Corp. & Subsidiaries (collectively, petitioner or affiliated group), which used the accrual method of accounting, implemented a proposed change in accounting method that accelerated approximately $5,010,305 of deductions for parts of certain liabilities attributable to periods after the close of petitioner’s TYE March 31, 2005. Petitioner contends it was entitled to accelerate its deductions for these expenses under the “all events” test of section 461 1 and/or the recurring item…

2Cases cited31 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States v. AndersonSupreme Court of the United States · 1926
  3. Helvering v. PowersSupreme Court of the United States · 1934
  4. Lash's Products Co. v. United StatesSupreme Court of the United States · 1929
  5. United States v. General Dynamics Corp.Supreme Court of the United States · 1987

26 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. The Morning Star Packing Company, L.P., The Morning Star Company, Tax Matters Partner v. CommissionerUnited States Tax Court · 2020
  2. Veco Corporation And Subsidiaries v. CommissionerUnited States Tax Court · 2013

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