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USFREIGHTWAYS CORP. & SUBS. v. COMMISSIONER

Docket No. 459-98.

113 T.C. 329 (1999)

USFREIGHTWAYS CORPORATION, F.K.A. TNT FREIGHTWAYS CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 2, 1999.

Attorney(s) appearing for the Case

Rex A. Guest and Melvin L. Katten, for petitioner.

Joseph P. Grant and Robin L. Herrell, for respondent.

OPINION

NIMS, Judge:

Respondent determined a Federal income tax deficiency for petitioner's 1993 taxable year in the amount of $1,712,070. After concessions, the issue for decision is whether petitioner, an accrual method taxpayer, may deduct costs expended for licenses, permits, fees, and insurance in the year paid rather than amortizing such costs over the taxable years to which they relate.

Unless...

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