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Giant Eagle, Inc. v. Commissioner

822 F.3d 666 (2016)

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Giant Eagle, Inc. v. Commissioner

United States Court of Appeals for the Third Circuit
822 F.3d 666 (2016)

Facts

Giant Eagle, Inc. (plaintiff) operated a chain of supermarkets, pharmacies, gas stations, and convenience stores. In 2004, Giant Eagle launched a customer-loyalty program called “fuelperks!,” which offered customers a 10-cent-per-gallon fuel discount for every $50 spent on qualifying groceries. A brochure stated that discounts expired three months after being earned and that Giant Eagle could end the program at any time; however, it did not otherwise indicate that accrued rewards could be revoked. In practice, Giant Eagle never ended the promotion or revoked earned rewards. Giant Eagle used the accrual method of accounting for tax-reporting purposes. For tax years 2006 and 2007, Giant Eagle claimed deductions for discounts customers had earned but not yet redeemed by year-end. The commissioner of the Internal Revenue Service (defendant) disallowed the deductions. Giant Eagle petitioned the tax court for a redetermination. The tax court affirmed the commissioner’s decision, holding that the deductions failed the “all events” test because Giant Eagle’s liability was not fixed at year-end. Giant Eagle appealed. On appeal, the commissioner conceded that the second and third prongs of the all-events test—reasonable accuracy and economic performance—were satisfied.

Rule of Law

Issue

Holding and Reasoning (Roth, J.)

Dissent (Hardiman, J.)

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