United States Seventh Circuit

Under Treasury Regulation Section 1.267(a)-3, deductions by a subsidiary to a parent company for interest payments must be taken when the interest payments were actually made, not simply when they accrued, if the related payee conducts its accounting using the cash method, even if it reports on the accrual basis.

Appellate Information

• Argued 10/25/2005
• Decided 02/13/2006
• Published 02/13/2006

Judges

• MANION, Circuit Judge., Before COFFEY, MANION, and KANNE, Circuit Judges.

Court

• United States Seventh Circuit

Counsel

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


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