Bob Wondries Motors, Inc. v. Commissioner

OPINION

RYMER, Circuit Judge:

Bob Wondries Motors, Inc., Toyota Town, Inc., Wondries Nissan, Inc., Country Nissan, Quality Motor Cars of Stockton, Bob Wondries Associates, Inc., Robert S. Zamora and Christina Zamora (taxpayers) appeal the Tax Court’s decision upholding tax deficiencies assessed by the Commissioner of the Internal Revenue Service.1 Taxpayers are automobile dealerships that deferred part of their prepaid services income from sales of extended warranty agreements, and they question whether they were also required to amortize related insurance expenses from the date of inception of…