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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
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