Kernrechtsfrage
Whether the customs back payment could be deducted as an expense in 2001 for direct federal tax.
Extrahierter Entscheid
No. The obligation arose in 2000, so the necessary provision had to be booked then; it could not be deferred to 2001 or 2002 to produce a tax effect.
Extrahierte Begründung
Under the accrual and periodicity principles, a necessary provision must be taken in the year in which the liability becomes apparent. Since the customs demand was known in 2000, the 2001 charge was correctly added back.