Johnson v. Commissioner
United States Tax Court
Ds sold multiyear vehicle service contracts (VSC's) in connection with the sale of motor vehicles under a common program administered by A, an unrelated party.
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Ds sold multiyear vehicle service contracts (VSC's) in connection with the sale of motor vehicles under a common program administered by A, an unrelated party. Under the terms of the program, Ds retained a portion of the contract price as their profit and remitted the remainder to A: (1) For deposit of a specified amount in escrow to fund their obligations under the VSC, and (2) for payment of A's fees and a premium for excess loss insurance provided by an unrelated insurance company. Ds currently included in gross income only the portion of the contract price that they retained as profit. Ds…
1Opinion of the Court
Beghe, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax, additions to tax, and penalties as follows:2
Rameau A. Johnson and Phyllis A. Johnson (the Johnsons), docket No. 16038-93.
Year Deficiency Penalty sec. 6662(a)
1991 $4,097 $819
Thomas R. Herring and Karon S. Herring (the Herrings), docket No. 16039-93.
Year Deficiency Penalty sec. 6662(a)
1991 $2,093 $419
dfm Investment Co., d.b.a. St. Louis Honda, docket No. 17007-93.
Year ended Deficiency Addition to tax sec. 6653(a) Penalty sec. 6662(a)
3/31/89 $2,285 $114 - 0 -
3/31/90 110,378 - 0 - $22,076
3/31/92 34,686 - 0 - 6,937
D…
2Cases cited83 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Davis v. Aetna Acceptance Co.Supreme Court of the United States · 1934
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
78 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- U.S. Freightways Corp., F.K.A. Tnt Freightways Corp., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
- Huffman v. Comm'rUnited States Tax Court · 2006
- Humphrey, Farrington & McClain, P.C. v. Comm'rUnited States Tax Court · 2013
- USFreightways Corp. v. CommissionerUnited States Tax Court · 1999
- Bob Wondries Motors, Inc. v. CommissionerCourt of Appeals for the Ninth Circuit · 2001
26 more not listed; retrieve them via the Exa API.