Legal Opinion

Brooks-Massey Dodge, Inc. v. Commissioner

United States Tax Court

Decided September 17, 1973No. Docket No. 489-71Published

1. The amounts of petitioner's dealer discount held back by the manufacturer under a plan agreed to by petitioner was taxable to petitioner in the years those amounts were credited by the manufacturer to petitioner's account rather than in the years in which those amounts were received by petitioner. 2. Respondent was justified in increasing the value of petitioner's yearend used-car inventory to 100 percent of the NADA guide list values from the 80 percent of such value…

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1. The amounts of petitioner's dealer discount held back by the manufacturer under a plan agreed to by petitioner was taxable to petitioner in the years those amounts were credited by the manufacturer to petitioner's account rather than in the years in which those amounts were received by petitioner. 2. Respondent was justified in increasing the value of petitioner's yearend used-car inventory to 100 percent of the NADA guide list values from the 80 percent of such value used by petitioner in determining taxable income. 3. Adjustments made by respondent under section 481 approved.

1Opinion of the Court

Brooks-Massey Dodge, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Brooks-Massey Dodge, Inc. v. Commissioner

Docket No. 489-71

United States Tax Court

60 T.C. 884; 1973 U.S. Tax Ct. LEXIS 58; 60 T.C. No. 94;

September 17, 1973, Filed

Decision will be entered for the respondent.

1. The amounts of petitioner's dealer discount held back by the manufacturer under a plan agreed to by petitioner was taxable to petitioner in the years those amounts were credited by the manufacturer to petitioner's account rather than in the years in which those amounts were received by petitioner.

2.…

2Cases cited23 opinions

  1. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
  2. Brown v. HelveringSupreme Court of the United States · 1934
  3. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  4. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  5. Schulde v. CommissionerSupreme Court of the United States · 1963

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