United States v. Consolidated Edison Co. of New York, Inc.

Consolidated Edison Company of New York (Edison) paid property taxes assessed by New York State from 1946 to 1951 in full each year to avoid foreclosure, despite believing the state's valuations were about 15% too high, and filed protests -- its only available means of challenging the assessments, which did not suspend the payment obligation. The protest process ultimately found the state had over-valued Edison's property by 5%, resulting in a refund. Edison, which used the accrual accounting method, had deducted its full 1951 tax payment, believing 15% of that payment had never truly accrued while the protest was pending; the IRS denied a related refund claim, and after the district court ruled for the government, the Second Circuit reversed, and the Supreme Court granted certiorari.