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Revenue Ruling 2007-3

Internal Revenue Service
2007-1 C.B. 350 (2007)

Written by Abby Roughton, JD

Facts

Corporation X used an accrual method of accounting and filed federal income-tax returns on a calendar-year basis. On December 15, 2006, X executed a contract with Y, pursuant to which Y was to provide services to X beginning on January 15, 2007. Payment was due under the contract on January 15, 2007. In a second scenario, on December 15, 2006, X executed a contract with W insurance company to obtain an insurance policy covering the period from January 15, 2007, through December 31, 2007. Under the contract, X’s premium payment was due to W on January 15, 2007. The Internal Revenue Service issued a revenue ruling to discuss when X incurred the liability to Y for services and the liability to W for insurance.

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