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Income Tax Keyed to Graetz
Ford Motor Company v. Commissioner
Citation:
71 F.3d 209 (6th Cir. 1995)Facts
Petitioner settled numerous tort claims against it and purchased annuities to cover the yearly amounts due to the claimants under various structured settlement agreements. Petitioner then deducted its calculation of the total amount of liabilities it had accrued due to the structured settlement agreements and reported the income from the annuities it had purchased. The Commissioner of Internal Revenue disallowed any deductions from the settlement agreements in excess of the cost of the annuities Petitioner had purchased to pay the tort claimants. The Commissioner of Internal Revenue devised a different method of accounting to clearly reflect the actual income received by Petitioner, pursuant to 26 U.S.C. § 446(b).
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