Wilkins Pontiac v. Commissioner
United States Tax Court
Petitioner, on an accrual basis, sold automobiles and received conditional sales contracts covering the balance of purchase price due. Petitioner sold these contracts to GMAC at face value without discount and guaranteed payment of the full amount due under the contracts. Held, petitioner may not deduct an addition to a "Reserve for Losses on Contracts Discounted" established to cover anticipated payments it will have to make in later years under its guaranty contract.
1Opinion of the Court
OPINION.
Deennen, Judge:
Respondent determined a deficiency in petitioner’s income tax for the year 1955 in the amount of $12,864.82. The sole issue is whether petitioner may deduct from its gross income a reasonable addition to a reserve for anticipated losses on conditional sales contracts which were sold with recourse.
All of the facts are stipulated and are so found.
Petitioner is a corporation organized and existing under the laws of the State of California with its principal offices in Van Nuys, California. Its tax return for the calendar year 1955 was filed with the district director of…
2Cases cited9 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Brown v. HelveringSupreme Court of the United States · 1934
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
4 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Western Oaks Bldg. Corp. v. CommissionerUnited States Tax Court · 1968
- Wilkins Pontiac v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Wilkins PontiacCourt of Appeals for the Ninth Circuit · 1961
- Glenn L. Bolling and Ila L. Bolling, Mae L. Hausmann, Fairhills Company, B & H Homes, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1966
- Burbank Liquidating Corp. v. CommissionerUnited States Tax Court · 1963
- Foster Frosty Foods, Inc. v. CommissionerUnited States Tax Court · 1963
15 more not listed; retrieve them via the Exa API.