It Has to Be Something! Tax Court Penalizes Taxpayer for Sloppy Records

We once again revisit the Cohan rule, but this time in the context of a much larger taxpayer than we normally look at, in the case of Tyson Foods, Inc and Subsidiaries vs. Commissioner, TC Memo 2007-188.  The taxpayer's was attempting to argue, based on Cohan rationalization, that they should be able to depreciate a $2,000,000+ debit remaining on their books after making an agreed upon adjustment under IRS exam.  The IRS (and eventually the Tax Court) did not agree that such a treatment should be allowed.The materials for the case are at http://www.edzollars.com/2007-07-21.pdf . The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com .