Gregory v. Comm'r
United States Tax Court
Ps own C, an S corporation that operates a landfill and uses the cash method of accounting for tax purposes. C is legally required to pay reclamation and closing costs if and when it closes the landfill. C currently deducted its estimated clean-up costs under I.R.C. section 468. R contends that I.R.C. section 468 applies only to accrual-method taxpayers.
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Ps own C, an S corporation that operates a landfill and uses the cash method of accounting for tax purposes. C is legally required to pay reclamation and closing costs if and when it closes the landfill. C currently deducted its estimated clean-up costs under I.R.C. section 468. R contends that I.R.C. section 468 applies only to accrual-method taxpayers. Held: The term "taxpayer" in I.R.C. section 468 includes cash-method taxpayers and is not limited to accrual-method taxpayers. I.R.C. sec. 468(a). Held, further, cash-method taxpayers must make an I.R.C. section 468 election to currently…
1Opinion of the Court
BOB GREGORY AND KAY GREGORY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent;
JAMES W. GREGORY, JR. AND JANET E. GREGORY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gregory v. Comm'r
Docket Nos. 17198-13, 17210-13.1
United States Tax Court
2017 U.S. Tax Ct. LEXIS 35; 149 T.C. No. 2;
July 11, 2017, Filed
Decisions will be entered for petitioners.
Ps own C, an S corporation that operates a landfill and uses the cash method of accounting for tax purposes. C is legally required to pay reclamation and closing costs if and when it closes the landfill. C currently deducted its…
Also in this document: Concurrence.
2Cases cited32 opinions
- Citizens to Preserve Overton Park, Inc. v. VolpeSupreme Court of the United States · 1971
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
- Smith v. DoeSupreme Court of the United States · 2003
- United States v. AndersonSupreme Court of the United States · 1926
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