William S. Gillis, and Loretta L. Gillis v. United States of America, United States of America v. William S. Gillis, and Loretta L. Gillis

GOLDBERG, Circuit Judge:

This suit for the refund of federal income taxes plus interest for the calendar years 1957 and 1958 presents two separate issues involving Internal Revenue Service objections to items returned as accruals by a partnership. The first issue concerns objections to the partnership’s taking as an accrued liability the estimated future sales losses in fulfilling its contractual obligations to export cotton under the regulations of the Commodity Credit Corporation. The second issue involves the question of whether the partnership was entitled to accrue and deduct in its 1958…