Quality Chevrolet Co. v. Commissioner
United States Tax Court
The petitioner sold automobiles on credit and discounted the promissory notes with several financial institutions. Such institutions established dealer reserve accounts to which were credited portions of the finance charges on the notes. Such portions were based upon anticipated full payment of the finance charges, and the petitioner reported as accrued income all such credits to its dealer reserve accounts.
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The petitioner sold automobiles on credit and discounted the promissory notes with several financial institutions. Such institutions established dealer reserve accounts to which were credited portions of the finance charges on the notes. Such portions were based upon anticipated full payment of the finance charges, and the petitioner reported as accrued income all such credits to its dealer reserve accounts. In the event a customer prepaid his note, the full finance charge would not be realized, and the financial institution would accordingly charge the petitioner's dealer reserve account…
1Opinion of the Court
Quality Chevrolet Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Quality Chevrolet Co. v. Commissioner
Docket No. 5887-64
United States Tax Court
50 T.C. 458; 1968 U.S. Tax Ct. LEXIS 113;
June 10, 1968, Filed
Decision will be entered under Rule 50.
The petitioner sold automobiles on credit and discounted the promissory notes with several financial institutions. Such institutions established dealer reserve accounts to which were credited portions of the finance charges on the notes. Such portions were based upon anticipated full payment of the finance charges, and the…
2Cases cited14 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Brown v. HelveringSupreme Court of the United States · 1934
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Harrold v. Commissioner of Internal Revenue. Cromling v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1951
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