Traditionally, generally accepted commercial accounting practices concerning prepaid income for goods and services have conflicted with the Internal Revenue Service's tax treatment of this income. The author examines the pertinent Internal Revenue Code sections, Supreme Court cases, Revenue Procedures and Treasury Regulations which have evolved from the attempts to reconcile these two positions. The author also suggests how the issue can be avoided altogether by using appropriate characterizations and planning.
David C. Long,
Prepayments: The Historical Tension between Tax and Commercial Accounting,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol21/iss1/6