Resale Mobile Homes, Inc. v. Commissioner
United States Tax Court
Petitioner, a Colorado corporation, was engaged in the business of selling new and used mobile homes at retail. Purchaser financing was provided by petitioner through arrangements with two finance companies.
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Petitioner, a Colorado corporation, was engaged in the business of selling new and used mobile homes at retail. Purchaser financing was provided by petitioner through arrangements with two finance companies. Pursuant to such arrangements, petitioner sold the consumer paper created from the credit sale to either of the finance companies, receiving in return the principal amount of the consumer paper plus participation interest based on the excess of the interest rate petitioner charged the purchaser over the rate the finance company charged petitioner. Prior to the years in dispute, the…
1Opinion of the Court
JACOBS, Judge:
Respondent determined deficiencies in
petitioner’s Federal income taxes in the following amounts:
TYE May 31— Deficiency
1978. $9,289
1979. 194,698
1980. 156,868
1981. 99,056
By its amended petition, petitioner claims entitlement to a refund of $3,015 as a result of a carryback (from its 1982 taxable year to its 1979 taxable year) of an investment tax credit. By his amended answer, respondent claims an increased deficiency in the amount of $9,302 with respect to petitioner’s 1980 taxable year based on an allegedly erroneous refund to petitioner.
After concessions, the issues for…
2Cases cited5 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- Munford, Inc. v. CommissionerUnited States Tax Court · 1986
- George K. Herman Chevrolet, Inc. v. CommissionerUnited States Tax Court · 1963
3Cited by12 opinions
- Johnson v. CommissionerUnited States Tax Court · 1997
- Charles Schwab Corp. v. CommissionerUnited States Tax Court · 1996
- Resale Mobile Homes, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992
- Continental Illinois Corp. v. CommissionerUnited States Tax Court · 1991
- Jerry Lipps, Inc. v. CommissionerUnited States Tax Court · 1990
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