USFreightways Corp. v. Commissioner
United States Tax Court
P, an accrual method taxpayer, made expenditures during the 1993 taxable year for licenses and insurance which had an effective period extending into 1994. For purposes of book accounting and financial reporting, P ratably allocated these costs over the periods to which they related. For tax accounting purposes, however, P currently deducted all license and insurance expenses in the year of payment.
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P, an accrual method taxpayer, made expenditures during the 1993 taxable year for licenses and insurance which had an effective period extending into 1994. For purposes of book accounting and financial reporting, P ratably allocated these costs over the periods to which they related. For tax accounting purposes, however, P currently deducted all license and insurance expenses in the year of payment. HELD: On the facts, P, as a taxpayer utilizing the accrual method, is not entitled to currently deduct costs benefiting future tax periods in the year of payment. R's determination of a deficiency…
1Opinion of the Court
USFREIGHTWAYS CORPORATION, F.K.A. TNT FREIGHTWAYS CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
USFreightways Corp. v. Commissioner
No. 459-98
United States Tax Court
113 T.C. 329; 1999 U.S. Tax Ct. LEXIS 50; 113 T.C. No. 23;
November 2, 1999, Filed
Decision will be entered under Rule 155.
P, an accrual method taxpayer, made expenditures during the
1993 taxable year for licenses and insurance which had an
effective period extending into 1994. For purposes of book
accounting and financial reporting, P ratably allocated these
costs over the periods to which they…
2Cases cited27 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Coors v. CommissionerUnited States Tax Court · 1973
- Adolph Coors Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1975
- United States v. Victor H. And Elsie Akin, Fred C. And Alice M. Kluver, E.F. And Gladys MunroeCourt of Appeals for the Tenth Circuit · 1957
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