| http://www.w3.org/ns/prov#value | - The United States Tax Court, William M. Fay, Judge, held that the prepayment was an interest expense in the year the payment was made under Section 163(a) of the Internal Revenue Code, 26 U.S.C. ?? 163(a), but also ruled that the Commissioner did not abuse his discretion under Section 446 of the Code, 26 U.S.C. ?? 446, by applying the accrual method of accounting to the payment and disallowing all
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