General Communication Co. v. Commissioner

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…