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Grynberg v. Commissioner

United States Tax Court
83 T.C. 255 (1984)


Facts

Jack Grynberg (plaintiff) owned many oil and gas leases across five states. Each of the leases contained a delay clause. Under the delay clause, Grynberg would owe an annual fee to be paid in the anniversary month of the specific lease if drilling operations did not occur. If Grynberg did not pay this fee promptly, the lease would automatically revert back to the owner. For all leases with an anniversary date between April and December, Grynberg paid the delay-clause fee one month before it was due. For all leases with an anniversary date between January and March, Grynberg paid the delay-clause fee in December of the prior year. Grynberg utilized the cash-basis method of accounting for tax purposes and recognized all of his expenses and gains at the time of actual payment or receipt. Grynberg deducted the January through March delay-clause payments in the prior year’s federal taxes. The commissioner of internal revenue (commissioner) (defendant) determined that the February and March delay-clause payments should be deducted in the year they were due. Grynberg petitioned the United States Tax Court for a redetermination.

Rule of Law

Issue

Holding and Reasoning (Swift, J.)

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