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in the dealer reserve account would in all events either be paid
to the taxpayer or be applied in satisfaction of his obligations,
whereas in the cases at hand the reserves might have been
disposed of in a manner that did not constitute "receipt" by the
Dealership. Specifically, there were two additional possible
scenarios: The reserves might be: (1) Paid to another repair
facility, or (2) refunded to the purchaser upon cancellation of
the contract.
The VSC imposes an obligation upon the issuing Dealership
either to perform covered repairs itself or to pay for covered
repairs by another authorized facility. The use of the reserves
to pay another authorized repair facility would discharge the
Dealership's obligation and thereby constitute "receipt" within
the meaning of Hansen. Commissioner v. Hansen, 360 U.S. at 465-
466; cf. Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-
730 (1929). The Dealership would also "receive" the reserves in
the second scenario posited by petitioners. Under the VSC, like
a standard contract of insurance which it closely resembles, upon
notification of the purchaser's election to cancel the contract,
the Dealership immediately becomes personally indebted to the
purchaser for the amount of the unearned portion of the contract
price. See 7 Williston on Contracts, sec. 920, at 618-619, 634
(3d ed. 1963). When the Dealership secures release of reserves
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