Lychuk v. Comm'r
United States Tax Court
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 services in paying the sellers.
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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 services in paying the sellers. R determined that all of A's salaries, benefits, and overhead (printing, telephone, computer, rent, and utilities) relating to its acquisition (and not to its service)…
1Opinion of the Court
DAVID J. LYCHUK AND MARY K. LYCHUK, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Lychuk v. Comm'r
No. 11794-99; No. 11855-99; No. 11863-99
United States Tax Court
116 T.C. 374; 2001 U.S. Tax Ct. LEXIS 28; 116 T.C. No. 27;
May 31, 2001, Filed
GALE, J., agrees with this concurring in part and dissenting in part opinion.
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…
Also in this document: Concurrence; Concurring in part, dissenting in part · Ruwe; Concurring in part, dissenting in part · Halpern; Concurring in part, dissenting in part · Beghe.
2Cases cited87 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
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