- 13 -
Reconciliation of deferred
interest account 1,596,968
Additional income reported
on amended return 425,955
Other income 5,107,102
Parenthetically, we note that the tax deficiency determined
by respondent was computed without taking into account the
limitation in tax provided by section 481(b), and
petitioner has not raised that as an issue in this case.
In reference to the additional income reported on
petitioner's amended return, $425,955, respondent concedes
that two of the items of additional income, the aggregate
payments to American Express of $168,854.36 and the
aggregate payments to Martin's Restaurant of $5,638.93,
duplicate the "Repossession Costs" adjustment of $175,104
determined in the notice of deficiency. We note that the
sum of the payments to American Express and Martin's
Restaurant is $174,493.29, or $610.71 less than the
adjustment for repossession costs. Petitioner concedes
that the remaining items reported on its amended return in
the aggregate amount of $251,462.15 are additional income.
OPINION
Change of Method of Accounting for Interest Income
The first issue for decision in this case involves
petitioner's method of accounting for the interest earned
on its portfolio of car loans. At the time each loan was
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011