The IRS has non-acquiesced to the Third Circuit decision in Giant Eagle, Inc vs Comm'r, 822 F.3d 666 (3rd Cir. 2016) rev'g T.C. Memo 2014-146.
This case dealt with deductions for anticipated customer redemptions of gasoline discounts under a shoppers? reward program.
Link to the AOD:
The decision is a highly technical one concerning how an accrual based taxpayer treats unredeemed customer loyalty credits.
Non-acquiescence means that, while the IRS lost in the 3rd Circuit and has to follow the ruling there, it won't follow the ruling in the rest of the county.
Interesting, thanks.
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