Supreme Court of the United States

Dixie Pine Products Co. v. Commissioner of Internal Revenue

January 3, 1944320 U.S. 516

Summary

The Court unanimously affirmed the disallowance of Dixie Pine Products Company's deduction for an unpaid Mississippi gasoline tax that the company was actively contesting in state court. Justice Roberts explained that an accrual-basis taxpayer may deduct an unpaid liability only when all events fixing its amount and existence have occurred. Because the company's liability remained contested, it could not deduct the assessment in 1937 and instead had to await final adjudication. The Board of Tax Appeals applied the correct legal rule, and the court below properly declined to disturb its determination. There were no separate opinions.

Holding

  • Deductibility of an unpaid and contested state tax liability under accrual accounting.. The taxpayer could not deduct the contested state tax assessment in 1937; it had to await final adjudication of its liability and could claim a deduction only for the taxable year in which liability was finally adjudicated.

Docket 84

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