§1165

e close of the taxable year shall include amounts which, because of contingencies, would not (but for this - 39 - section) be deductible under section 162(a) as an accrued expense. * * * [Emphasis added.] The Tax Reform Act of 1986, Pub. L. 99-514, sec. 1165(a), 100 Stat. 2511, amended section 463(a)(1) for tax years beginning after December 31, 1986. Prior to the amendment, the section read "and expected to be paid during the taxable year or within 12 months following the close of the taxable y