GMC v. Comm'r
United States Tax Court
GM and GMAC are members of a consolidated group. GM manufactured motor vehicles. GMAC financed motor vehicles. HELD: The consolidated return regulations in issue constituted a method of reporting and not a method of accounting. Henry C. Beck Co. v. Commissioner, 52 T.C. 1 (1969), affd. per curiam 433 F.2d 309 (5th Cir. 1970), and Henry C. Beck Builders, Inc. v. Commissioner, 41 T.C. 616 (1964), followed.
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GM and GMAC are members of a consolidated group. GM manufactured motor vehicles. GMAC financed motor vehicles. HELD: The consolidated return regulations in issue constituted a method of reporting and not a method of accounting. Henry C. Beck Co. v. Commissioner, 52 T.C. 1 (1969), affd. per curiam 433 F.2d 309 (5th Cir. 1970), and Henry C. Beck Builders, Inc. v. Commissioner, 41 T.C. 616 (1964), followed. HELD, FURTHER, GM's rate support deductions are not subject to deferral pursuant to sec. 1.1502-13(b)(2), Income Tax Regs.
1Opinion of the Court
GENERAL MOTORS CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
GMC v. Comm'r
No. 27026-96
United States Tax Court
112 T.C. 270; 1999 U.S. Tax Ct. LEXIS 22; 112 T.C. No. 19;
May 25, 1999, Filed
An appropriate order will be issued.
GM and GMAC are members of a consolidated group. GM manufactured motor vehicles. GMAC financed motor vehicles. HELD: The consolidated return regulations in issue constituted a method of reporting and not a method of accounting. Henry C. Beck Co. v. Commissioner, 52 T.C. 1 (1969), affd. per curiam 433 F.2d 309 (5th Cir. 1970), and…
2Cases cited9 opinions
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
- Diebold, Incorporated v. The United StatesCourt of Appeals for the Federal Circuit · 1990
- Diebold, Inc. v. United StatesUnited States Court of Claims · 1989
- Henry C. Beck Co. v. CommissionerUnited States Tax Court · 1969
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