United States v. Anderson

In United States v. Anderson, 269 U.S. 422, 441 (1926), the Court held that a taxpayer was obliged to deduct from its 1916 income a tax on profits from munitions sales that took place in 1916. Although the tax would not be assessed and therefore would not formally be due until 1917, all the events which fixed the amount of the tax and determined the taxpayer's liability to pay it had occurred in 1916. The test is now embodied in Treas. Reg. 1.461-1(a)(2), 26 CFR 1.461-1(a)(2) (1986), which provides that "under an accrual method of accounting, an expense is deductible for the taxable year in which all the events have occurred which determine the fact of the liability and the amount thereof can be determined with reasonable accuracy.