points became fixed. Gold Coast analogized their case to a Supreme Court decision in which the Court held that a casino could deduct the guaranteed payment accrued by progressive slot machines, even though the jackpot had not been won by the end of the tax year. The Commissioner argued that, with respect to the slot club points, liability of the casino did not arise until members actually redeemed their points for prizes. Therefore, the casino should not be allowed to deduct as expenses those points which have not been redeemed. The Commissioner stressed that not all slot club members will choose to redeem their points, therefore Gold Coast's liability is not fixed until the points are actually redeemed. The commissioner relied on a previous Supreme Court decision that held that an employer that self-insured its employees' medical plan could not deduct the amount of money placed in a reserve account until reimbursement claims were actually filed. Holding Gold Coast's deductions were proper, as its liability to members became fixed upon their accumulation of the minimum number of club points whether or not they chose to redeem them and because the amount of liability was known with reasonable certainty. Reasoning First prong: the all-events test: The court found that the "fundamental premise" underlying the all-events test is that expenses may not be deducted until liability is firmly established. Therefore, the liability must be fixed and unconditional and not contested or contingent upon a future event. The court disagreed with the Commissioner as to the timing of when Gold Coast became liable to its slot club members. It rejected the Commissioner's claim that liability was not fixed until a customer redeemed his or her slot club point. Instead, the court held that Gold Coast's liability became fixed upon a member accumulating the minimum number of points required to redeem a prize. Quoting United States v. Hughes Properties, Inc., the court found that "[t]he existence of an absolute liability is necessary; absolute certainty that it will be discharged by payment is not." Therefore, just because a club member might choose not to redeem his or points in a certain year does not mean that Gold Coast's liability is not fixed. Furthermore, Gold Coast will simply recapture as income those liabilities that were not discharged by redemption of the points in the next year. Second prong: liability must be determined with reasonable certainty:The court