Brooks-Massey Dodge, Inc. v. Commissioner
United States Tax Court
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
DreNNEN, Judge:
Respondent determined deficiencies in petitioner's corporate income taxes in the amounts of $30,411.83 and $16,318.75 for the tax years 1967 and 1968, respectively. Petitioner has abandoned one issue on brief, and two questions remain for our decision:(1) Whether petitioner may use a hybrid form of the cash receipts and disbursements method of accounting to reflect income from manufacturer discount holdbacks on automobiles purchased from the manufacturer and sold to customers.(2) Whether petitioner may use 80 percent of the NADA wholesale value as the adjusted yearend value of…
2Cases cited22 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Brown v. HelveringSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
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