Under Regulation Section 1.461-1(a)(2)(i), an accrual basis taxpayer cannot deduct a liability until three tests are met.

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If Robco is an accrual basis corporation it can accrue the salary due to Terry and pay it to Terry, a cash basis taxpayer in the subsequent year.

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Again, to deduct a bad debt, you must have previously included the amount in your income (for accrual basis taxpayers) or actually loaned cash to a third party.

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