Foretravel, Inc. - Page 26

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            suspense account that needed to be adjusted later in order to                                  
            reclassify the rebates.  Golden did not reclassify the incentive                               
            payments for financial accounting purposes because he felt that                                
            doing so would not change the consolidated financial statements                                
            prepared by Axley & Rode.  Golden failed to reclassify the                                     
            rebates, and when the Axley & Rode tax department prepared                                     
            petitioner's Federal corporate income tax returns, nothing                                     
            indicated that rebates to the dealers existed.  When Golden                                    
            reviewed the completed tax returns, he compared the results with                               
            preliminary calculations he made using the financial statements,                               
            but he failed to notice that the incentive payments had not been                               
            reclassified.  Weaver reviewed petitioner's Federal corporate                                  
            income tax returns for the years in issue, but he failed to                                    
            realize that Axley & Rode had not reclassified the incentive                                   
            payments.  As a result, petitioner reported the rebates as bad                                 
            debts on its tax returns for the years in issue.  The incentive                                
            payments were booked on the subsidiaries' financial statements                                 
            for the years 1989 and 1990 as other income.  For the years in                                 
            issue, the subsidiaries reported the incentive payments as income                              
            in an amount equal to the bad debt deductions taken by                                         
            petitioner.                                                                                    
                                                 OPINION                                                   
            Deduction for Payments Made in Connection With Northwest                                       
                  The differences between the parties come down to a basic                                 
            difference in the analysis and interpretation of the events that                               




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Last modified: May 25, 2011