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
RAMEAU A. AND PHYLLIS A. JOHNSON, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Johnson v. Commissioner
Docket Nos. 16038-93, 16039-93, 17007-93, 14430-94
United States Tax Court
108 T.C. 448; 1997 U.S. Tax Ct. LEXIS 51; 108 T.C. No. 22;
June 16, 1997, Filed
Decisions will be entered under Rule 155.
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…
2Cases cited84 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
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