ABC Rentals of San Antonio, Inc., et al - Page 15

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          units to third parties by category, such percentage being equal             
          to the ratio such total sales proceeds bore to the total initial            
          purchase price of all rental units in that category, was as                 
          follows:                                                                    
          Category                              Percentage                            
                    Guaranteed                              ABC                       
          Appliances                    2.0                 2.7                       
          Televisions                   Less than 1         5.5                       
          Furniture                     2.3                 2.4                       
          Stereos                       Less than 1    Less than 1                    
          Video Cassette Recorders      Less than 1    Less than 1                    
               The total initial cost of rental units acquired during the             
          years 1987 and 1988 and which remained in Guaranteed's rental               
          inventory as of the end of the years was $142,173.71 and                    
          $117,812.45, respectively.  The total initial cost of rental                
          units acquired during the tax periods ending May 31, 1987,                  
          December 31, 1987, and December 31, 1988, and which remained in             
          ABC's rental inventory as of the end of the periods was                     
          $273,435.20, $137,102.89, and $328,557.04, respectively.                    
                                       OPINION                                        
               The U.S. Court of Appeals for the Tenth Circuit has directed           
          us to determine:  (1) Whether petitioners made a proper election            
          under section 168(f) and, (2) if a proper election was made under           
          section 168(f), whether petitioners improperly applied the income           
          forecast method because they did not accurately forecast the                







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