- 11 - section 1.458-1, Income Tax Regs., remained essentially identical in the final version. They provide: (c) Amount of the exclusion -- (1) In general. Except as otherwise provided in paragraph (g) of this section, the amount of the gross income exclusion with respect to any qualified sale is equal to the lesser of -- (i) [same as section 458(b)(6)(A)] (ii) [same as section 458(b)(6)(B)] * * * * * * * (g) Adjustment to inventory and cost of goods sold. (1) If a taxpayer makes adjustments to gross receipts for a taxable year under the method of accounting described in section 458, the taxpayer, in determining excludable gross income, is also required to make appropriate correlative adjustments to purchases or closing inventory and to cost of goods sold for the same taxable year. Adjustments are appropriate, for example, where the taxpayer holds the merchandise returned for resale or where the taxpayer is entitled to receive a price adjustment from the person or entity that sold the merchandise to the taxpayer. Cost of goods sold must be properly adjusted in accordance with the provisions of sec. 1.61-3 which provides, in pertinent part, that gross income derived from a manufacturing or merchandising business equals total sales less cost of goods sold. The correlative adjustments contemplated by the Regulation are illustrated by examples in subparagraph 2. In Example 1, which we shall adapt somewhat for the purposes of our discussion, publisher sells 500 copies of its publication to distributor at $1 each in year 1. Under the sale agreement publisher has an obligation to refund to distributor the full sales price for any copies which distributor does not resell and returns, or from which distributor removes and returns the cover, during thePage: 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