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For Federal income tax purposes, the debt's conversion feature is ignored; interest accrues
at the debt instrument's overall yield based on the stated interest rate and any OID.
Accordingly, W accrues
$13,000 of gross sales and includes $13,000 (less the corresponding cost of goods sold) in gross income in 2002, because the all-events test is met.
1991, a taxpayer was held to the contract terms of a loan document and was required to accrue
interest when the taxpayer did not formally declare the notes to be in default.
Example 1: BA, an accrual-basis partnership, accrues
an otherwise deductible expense to partnership CA, which is on the cash basis.
Some of these arrangements also provide for "interest" to accrue
on the amounts deferred until the benefits are paid to the participants.