- 23 - Capital Gain 65 --- --- Annuity Received by Mrs. Sutton --- 13,065 $13,068 Inherited IRA --- 23,579 --- Interest Income --- 605 --- OPINION The Corporate Petitioner Rebate and Coupon Checks The corporate petitioner acknowledges that rebates are to be considered in calculating its income. In some instances, the corporate petitioner recorded rebates as a reduction to cost of sales and in other instances, where rebates had been credited against amounts owed to wholesalers, the corporate petitioner reflected the net costs. Respondent agrees with that treatment. To the extent, however, that the proceeds of rebate checks were not accounted for by either of those methods, we hold that the corporate petitioner had unreported income from rebate checks.8 In other words, if the rebate checks did not in some way reduce cost of sales, then the cost of sales was overstated, and the gross income was correspondingly understated. The parties also agree that the coupons result in income; they disagree, however, as to the proper treatment of that income. Respondent has determined that the corporate 8 Petitioners have speculated that some rebate checks may have been rung up on the register, thereby being included in income twice, once in cash register gross receipts and again as a result of reducing cost of sales as a rebate. Petitioners have not established any such instances.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011