Vander Poel, Francis & Co., Inc. v. Commissioner

The corporation (plaintiff) voted to pay salaries to its two officers and unconditionally credited their accounts in 1942, but the salaries weren't actually paid until after 1942; the corporation sought to deduct the full credited amount in 1942, arguing that just as a taxpayer can be taxed on constructively received (but not actually received) income, a corporation should similarly be able to deduct constructively paid (but not actually paid) salaries.