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SQUARE D CO. AND SUBSIDIARIES v. C.I.R.

No. 04-4302.

438 F.3d 739 (2006)

SQUARE D COMPANY AND SUBSIDIARIES, Petitioner-Appellant, v. COMMISSIONER OF THE INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided February 13, 2006.

Attorney(s) appearing for the Case

Thomas V. Linguanti (argued), Baker & McKenzie, Chicago, IL, for Petitioner-Appellant.

Michael J. Haungs (argued), Department of Justice Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee.

Before COFFEY, MANION, and KANNE, Circuit Judges.

MANION, Circuit Judge.

Square D Company attempted to take deductions for certain interest payments to its French parent that accrued in 1991 and 1992. Relying on Treasury Regulation § 1.267(a)-3, the Commissioner of the Internal Revenue Service adopted the position that any such deductions had to be taken when the interest payments were actually made, not when they accrued. Square D challenged this regulation and the Commissioner's actions before the Tax Court...

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