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NOTES 451 Tax Lawyer, Vol. 56, No. 2 NOTE A STRAIN BETWEEN THE CONTESTED TAX LIABILITY ACCRUAL DOCTRINE AND THE ACCUMULATED EARNINGS TAX: METRO LEASING AND DEVELOPMENT CORPORATION V. COMMISSIONER In Metro Leasing and Development Corp. v. Commissioner,1 the Tax Court held that no part of a paid, but contested, income tax deficiency could be used to reduce the taxpayer’s taxable income in arriving at accumulated earnings taxable income.2 The court rejected the taxpayer’s reliance on the holding of...

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