- 26 - 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 thatPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011