David J. Lychuk and Mary K. Lychuk v. Commissioner

116 T.C. No. 27

UNITED STATES TAX COURT DAVID J. LYCHUK AND MARY K. LYCHUK, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 11794-99, 11855-99, Filed May 31, 2001. 11863-99. A acquires and services multiyear installment contracts as its sole business operations. A acquires each contract at 65 percent of its face value and is entitled to all principal and interest payments. A’s employees perform various credit review services in order to decide whether to acquire each contract offered to A and, as to the contracts which A chooses to acquire, perform additional…