3rd Circ. Sides With Giant Eagle In IRS Fuel Perks Tax Row

Law360, New York (May 6, 2016, 7:02 PM EDT) -- The Third Circuit in a 2-1 decision Friday said supermarket chain Giant Eagle Inc. was entitled to a $3.7 million tax deduction on loyalty rewards that shoppers had earned but not redeemed, reversing a decision by the U.S. Tax Court that the liabilities were not yet fixed.

The Tax Court — and the Internal Revenue Service — in denying the deduction misapplied the so-called all events test, which stems from a 1926 U.S. Supreme Court decision and says that a liability may accrue for tax purposes in a year in which all the events have occurred that establish the fact of...

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