Tag Archives: tobacco

Tax Court Rules that Payments by Tobacco Distributor to Tobacco Master Settlement Agreement Qualified Settlement Fund Not Deductible Until Paid

In Suriel v. Comm’r, 141 T.C. No. 16 (Dec. 4, 2013), the Tax Court ruled that, under the specific facts in this case, the economic performance rules under IRC Section 461(h), permitting a tax deduction for certain liabilities when a liability is fixed and before the liability is actually paid, did not trump the qualified … Continue Reading

Supreme Court Denies Cert on Preclusion Issue Post Decertification in Florida Tobacco Case…And Once Again, Decertification Proves to Be a Hollow Victory

Last week, on November 26, 2012, the United States Supreme Court denied cert in one of the thousands of individual cases pending in the aftermath of Engle v. Liggett Group, Inc., 945 So. 2d 1246 (Fla. 2006), where the State of Florida took on the tobacco industry.  In R.J. Reynolds Tobacco Co. v. Clay, Case … Continue Reading
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