- 16 - Dealerships distributed to their customers emphasized that "Insurance for this plan is provided by one of the six largest property and casualty insurance companies in the United States", and the manager of Alton Toyota/Dodge during the years at issue kept a red Travelers umbrella in his office to use as part of his sales presentation. On the other hand, neither the manager of Alton Toyota/Dodge nor the salesmen of the Dealerships generally called attention to the PLRF arrangement in their presentations to customers and did not show them the Administrator Agreement that governed the PLRF arrangement. No contract holder has ever requested API to furnish information regarding the status of a PLRF account. All of the Dealerships maintained their books and records under the accrual method of accounting. On their Federal income tax returns for each of the years at issue, the Dealerships reported as income from the sale of VSC's only that portion of the contract price that they retained as profit. The PLRF accounts were not reflected on the Dealerships' returns for these years, and the income earned by investment of these reserves was not currently included in their gross income. The Dealerships included reserves in income only when, and to the extent, paid to them from the PLRF accounts. For calendar year 1992 and subsequent years, the Escrow Trustees have filed Forms 1041, U.S. Fiduciary Income Tax Return,Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011