Question: Taxpayer is on a cash method of accounting for Tax purposes: At the end of the Year 1 the taxpayer records payroll for the last week of the year and process the payroll on December 31 of Year 1 with the Payroll company. The payroll checks are deliver to the employees on January 4 , of the following year. Can the payroll expense be deducted in year 1 ? Review the following tax rules and court cases: - IRC Sect. 446 - IRC Sect. 451(a) - REGS Sect. 1.451-1(a) - REGS Sect. 1.451-2 - Cowden v. Commissioner, 289 F.2nd 20 (5th Cir. 1961) - Kahler v. Commissioner USTC, 1951. 18 T.C. 31 - Vander Poel, Francis \& Co., Inc. v. Commissioner USTC, 1947. 8 T.C. 407 To research the matter and present your answer in the IRAC format (the handout is in the Resources Section of Brightspace)