In Hillsboro National Bank v. Commissioner (1983) 460 U.S. 370, the respondent corporation, which operated a dairy, deducted the full cost of cattle feed purchased for use in its operations under Internal Revenue Code section 162(a). Then, two days into the next taxable year, respondent liquidated and distributed its assets, including the cattle feed, to its shareholders. (460 U.S. at p. 374.) "Relying on Internal Revenue Code section 336, which shields a corporation from the recognition of gain on the distribution of property to its shareholders on liquidation, respondent reported no income on the transaction." (460 U.S. at pp. 374-375.) The United States Supreme Court determined that the tax benefit rule, which requires the inclusion of income when events occur that are fundamentally inconsistent with an earlier deduction, required the respondent to recognize income with respect to the distribution of expensed assets (which had been previously deducted as a business expense) to its shareholders on liquidation. (460 U.S. at p. 372.) Thus, where a taxpayer deducts the cost of an asset as an " 'ordinary and necessary expense' " under Internal Revenue Code section 162(a) but later sells the asset rather than consuming it while carrying on the trade or business, the taxpayer "would lose the deduction, for the basis of the asset would be zero , so the taxpayer would recognize the full amount of the proceeds on sale as gain." (460 U.S. at p. 395.)