CHALLENGE PUBLICATIONS, INC. v. C.I.R.

No. 87-7234.

845 F.2d 1541 (1988)

CHALLENGE PUBLICATIONS, INC., Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Memorandum March 2, 1988.

Decided May 6, 1988.


Attorney(s) appearing for the Case

Irving M. Grant, Hufstedler, Miller, Carlson & Beardsley, Los Angeles, Cal., for petitioner-appellant.

William S. Rose, Jr., Acting Asst. Atty. Gen., Ann Belanger Durney, Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before CANBY and WIGGINS, Circuit Judges, and LOVELL, District Judge.


WIGGINS, Circuit Judge:

Appellant, Challenge Publications, Inc. ("Challenge"), appeals the Tax Court's decision affirming $2,560,368 in deficiencies imposed by the Commissioner for the tax years 1972 through 1976. The Tax Court ruled that Challenge could not accrue as a deductible business expense an estimate for unsold magazines that it anticipated would be returned. Appellant claims that this practice satisfies the "all...

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