United States v. General Dynamics Corp.

United States v. General Dynamics Corp., 481 U.S. 239 (1987), is a United States Supreme Court case, which hold that under 162(a) of the Internal Revenue Code (26 U.S.C. 162(a)) and Treasury Regulation 1.461-1(a)(2) ( 26 CFR 1.461-1(a)(2)), the "all events" test entitled an accrual-basis taxpayer to a federal income tax business-expense deduction, for the taxable year in which (1) all events had occurred which determined the fact of the taxpayer's liability, and (2) the amount of that liability could be determined with reasonable accuracy.

Background

Facts

The corporation used the accrual method of accounting for federal tax purposes; its fiscal year was the same as the calendar year. From 1962 until October 1, 1972, the corporation purchased group-medical insurance for its employees and qualified dependents from two private insurance carriers. Beginning in October 1972, the corporation became a self-insurer with regard to its medical care plans. Instead of continuing to purchase insurance from outside carriers, it undertook to pay medical claims out of its own funds, while continuing to employ private carriers to administer the medical care plans.

An accrual-basis employer—a corporation which filed a consolidated federal income tax return with several subsidiaries--(1) reimbursed employees for certain medical expenses of employees and their qualified dependents; (2) established reserve accounts to reflect the employer's liability for medical care which had been received by covered individuals during the last quarter of 1972, but still not paid for by the employer as of December 31, 1972; (3) calculated the amount of the reserve based upon an estimate of the aggregate liability to be incurred for the period in question; and (4) claimed the estimated reserve as a business expense in an amended 1972 federal income tax return.

Audit

The Internal Revenue Service (IRS) audited appellee corporation's 1972 tax return. The corporation filed an amended return, claiming it was entitled to deduct its reserve as an accrued expense, and seek a refund. The IRS disallowed the deduction.