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item (the rate support payment) was not an expense (deduction)
for one member of the group (GM) and income for another member
(GMAC). The payment GM made to GMAC (which was the deduction)
was not directly related to the payments the retail/fleet
customers made to GMAC (which contained the discount income).
Additionally, here the money left the consolidated group.
Compare the examples of rate supported and nonrate-supported
RISC's bearing a below-market rate of interest. See supra pp.
33-36. In the example of a nonrate-supported RISC bearing a
below-market rate of interest, GMAC paid the independent GM
dealer $9,500. Thus, the GM group's total net expense was
$9,500. In the example of a rate-supported RISC, GMAC paid the
independent GM dealer $10,000 and GM paid GMAC $500. Thus, the
GM group's total net expense was $10,000. Five hundred dollars
($500) more left the GM group when a below-market RISC/fleet loan
was rate supported as compared with when there was no rate
support.
As respondent pointed out on brief, the matching rule
ensures clear reflection of income and prevents the creation of
"paper" deductions when the group as a whole has not incurred a
net expense. Here, the group had a net expense.
Furthermore, the GM group's additional $500 expense was a
real loss of $500 to the GM group. In both the example of a
nonrate-supported RISC and a rate-supported RISC bearing a below-
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