GMC v. Comm'r
United States Tax Court
GM and GMAC are members of a consolidated group. GM manufactured motor vehicles. GMAC financed motor vehicles. HELD: The consolidated return regulations in issue constituted a method of reporting and not a method of accounting. Henry C. Beck Co. v. Commissioner, 52 T.C. 1 (1969), affd. per curiam 433 F.2d 309 (5th Cir. 1970), and Henry C. Beck Builders, Inc. v. Commissioner, 41 T.C. 616 (1964), followed.
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GM and GMAC are members of a consolidated group. GM manufactured motor vehicles. GMAC financed motor vehicles. HELD: The consolidated return regulations in issue constituted a method of reporting and not a method of accounting. Henry C. Beck Co. v. Commissioner, 52 T.C. 1 (1969), affd. per curiam 433 F.2d 309 (5th Cir. 1970), and Henry C. Beck Builders, Inc. v. Commissioner, 41 T.C. 616 (1964), followed. HELD, FURTHER, GM's rate support deductions are not subject to deferral pursuant to sec. 1.1502-13(b)(2), Income Tax Regs.
1Opinion of the Court
OPINION
VASQUEZ, Judge:
Respondent determined a deficiency of $339,076,705 in petitioner’s 1985 consolidated Federal income tax. The issues in this case, the rate support and the special tools issues, have been bifurcated for separate resolution. This opinion addresses the rate support issues.
After concessions by the parties,1 the issues for decision are: (1) Whether General Motors Corp. (GM) and its consolidated affiliated subsidiaries (together, the GM group) changed its method of accounting, and (2) whether section 1.1502-13(b)(2), Income Tax Regs., requires GM to defer its deduction of…
2Cases cited8 opinions
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
- Diebold, Incorporated v. The United StatesCourt of Appeals for the Federal Circuit · 1990
- Diebold, Inc. v. United StatesUnited States Court of Claims · 1989
- Henry C. Beck Co. v. CommissionerUnited States Tax Court · 1969
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3Cited by4 opinions
- Guidant LLC v. Comm'rUnited States Tax Court · 2016
- Uniquest Del. LLC v. United StatesDistrict Court, W.D. New York · 2018
- GMC v. Comm'rUnited States Tax Court · 1999
- Greiner v. United StatesUnited States Court of Federal Claims · 2015