Foretravel, Inc. - Page 2

                                                  - 2 -                                                    
                  After concessions by the parties, the issues for decision                                
            are:                                                                                           
                  (1)  Whether petitioner is entitled to a deduction for its                               
            fiscal year ended June 30, 1989, in the amount of $1,933,994.10                                
            advanced to solve the financial problems of a dealership.  We                                  
            hold that petitioner is so entitled.                                                           
                  (2)  Whether petitioner is entitled to exclude from gross                                
            income, or deduct under section 162, in its fiscal years ended                                 
            June 30, 1989, and June 30, 1990, the respective amounts of                                    
            $1,160,673.58 and $2,510,135.98 as incentives to its dealerships.                              
            We hold that petitioner is entitled to exclude the respective                                  
            amounts from gross income.                                                                     
                  (3)  Whether petitioner is liable for an addition to tax                                 
            pursuant to section 6661 for its fiscal year ended June 30, 1989.                              
            We hold that petitioner is not.                                                                
                  (4)  Whether petitioner is liable for an addition to tax                                 
            pursuant to section 6662 for its fiscal year ended June 30, 1990.                              
            We hold that petitioner is not.                                                                
                  All section references are to the Internal Revenue Code in                               
            effect for the years in issue, and all Rule references are to the                              
            Tax Court Rules of Practice and Procedure, unless otherwise                                    
            indicated.                                                                                     
                                           FINDINGS OF FACT                                                
                  Some of the facts are stipulated and are so found.  We                                   






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011