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2006

Case Western Reserve University School of Law

Tax Law

Ation

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Hughes Properties And General Dynamics: The Supreme Court, The All Events Test, And The 1984 Tax Act, Erik M. Jensen Jan 2006

Hughes Properties And General Dynamics: The Supreme Court, The All Events Test, And The 1984 Tax Act, Erik M. Jensen

Faculty Publications

This article discusses United States v. Hughes Properties, a 1986 case in which the Supreme Court blessed an accrual-basis taxpayer's current deduction for amounts guaranteed as payoffs on progressive slot machines but for which no winner had yet been determined. The author notes that, had the case been governed by section 461(h) of the Internal Revenue Code, as it was amended by the 1984 Tax Reform Act, the deductions would have been deferred. He speculates about the Supreme Court's willingness to decide an issue rendered moot by subsequent legislation, and ponders the effect that the decision in ...