Application of The Test
Applying the test above, the Grynberg court concluded that the prepayments satisfied the first prong. The prepayments were not mere deposits but irretrievable payments. However, the court found no valid business reason for making the payments in December rather than the following February or March when the payments were actually due. Because taxpayers failed the second prong of the test, the court did not apply the third requirement to the facts of the case. Because the prepayments were not necessary and ordinary business expenses for the year in which they were paid, the prepayments were not deductible.
Read more about this topic: Grynberg V. Commissioner
Famous quotes containing the words application of the, application of, application and/or test:
“By an application of the theory of relativity to the taste of readers, to-day in Germany I am called a German man of science, and in England I am represented as a Swiss Jew. If I come to be regarded as a bête noire the descriptions will be reversed, and I shall become a Swiss Jew for the Germans and a German man of science for the English!”
—Albert Einstein (1879–1955)
“The main object of a revolution is the liberation of man ... not the interpretation and application of some transcendental ideology.”
—Jean Genet (1910–1986)
“We will not be imposed upon by this vast application of forces. We believe that most things will have to be accomplished still by the application called Industry. We are rather pleased, after all, to consider the small private, but both constant and accumulated, force which stands behind every spade in the field. This it is that makes the valleys shine, and the deserts really bloom.”
—Henry David Thoreau (1817–1862)
“We do not quite say that the new is more valuable because it fits in; but its fitting in is a test of its value—a test, it is true, which can only be slowly and cautiously applied, for we are none of us infallible judges of conformity.”
—T.S. (Thomas Stearns)