Arguments
Gold Coast argues that its deductions were proper because, using the all-events test, the last event that determined its liability occurred when the minimum number of slot club points needed to earn a prize is accumulated by a member, because under law the customer’s right to the points became fixed. Gold Coast analogized their case to a Supreme Court decision in which the Court held that a casino could deduct the guaranteed payment accrued by progressive slot machines, even though the jackpot had not been won by the end of the tax year.
The Commissioner argued that, with respect to the slot club points, liability of the casino did not arise until members actually redeemed their points for prizes. Therefore, the casino should not be allowed to deduct as expenses those points which have not been redeemed. The Commissioner stressed that not all slot club members will choose to redeem their points, therefore Gold Coast's liability is not fixed until the points are actually redeemed. The commissioner relied on a previous Supreme Court decision that held that an employer that self-insured its employees’ medical plan could not deduct the amount of money placed in a reserve account until reimbursement claims were actually filed.
Read more about this topic: Gold Coast Hotel & Casino V. United States
Famous quotes containing the word arguments:
“We are seeing an increasing level of attacks on the “selfishness” of women. There are allegations that all kinds of social ills, from runaway children to the neglected elderly, are due to the fact that women have left their “rightful” place in the home. Such arguments are simplistic and wrongheaded but women are especially vulnerable to the accusation that if society has problems, it’s because women aren’t nurturing enough.”
—Grace Baruch (20th century)
“The conclusion suggested by these arguments might be called the paradox of theorizing. It asserts that if the terms and the general principles of a scientific theory serve their purpose, i. e., if they establish the definite connections among observable phenomena, then they can be dispensed with since any chain of laws and interpretive statements establishing such a connection should then be replaceable by a law which directly links observational antecedents to observational consequents.”
—C.G. (Carl Gustav)
“Compared to football, baseball is almost an Oriental game, minimizing individual stardom, requiring a wide range of aggressive and defensive skills, and filled with long periods of inaction and irresolution. It has no time limitations. Football, on the other hand, has immediate goals, resolution on every single play, and a lot of violence—itself a highlight. It has clearly distinguishable hierarchies: heroes and drones.”
—Jerry Mander, U.S. advertising executive, author. Four Arguments for the Elimination of Television, ch. 15, Morrow (1978)