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
SimpsoN, Judge:
The respondent determined deficiencies in income tax of the petitioner of $11,503.21 for its taxable year 1960, $1,708.28 for its taxable year 1961, and $10,319.77 for its taxable year 1962. The only issue remaining for decision is whether the petitioner may deduct additions to its reserve for bad debts to provide for anticipated losses due to the prepayments of promissory notes by its customers.
FINDINGS OP PACT
All of the facts were stipulated, and those facts are so found.
The petitioner, Quality Chevrolet Co., Inc., was incorporated under the laws of the State of Kansas on…
2Cases cited13 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
8 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- S. Garber, Inc. v. CommissionerUnited States Tax Court · 1969
- Maryland Savings-Share Insurance v. United StatesUnited States Court of Claims · 1981
- Jostens, Inc. v. CommissionerUnited States Tax Court · 1989
- Collegiate Cap & Gown Co. v. CommissionerUnited States Tax Court · 1978
- Quality Chevrolet Co. v. CommissionerUnited States Tax Court · 1968
1 more not listed; retrieve them via the Exa API.