- 54 - market rate of interest, the RISC's had face values of $10,000 and stated interest of $2,000. See supra pp. 33-36. Thus, if GMAC held the below-market nonrate-supported RISC to maturity the GM group made a $2,500 profit ($12,000 minus the $9,500 paid to the independent GM dealer), or if the customer paid off the RISC immediately the GM group made a $500 profit (the $10,000 of stated principal minus the $9,500 paid to the independent GM dealer). Whereas, if GMAC held the rate-supported RISC to maturity the GM group made a $2,000 profit ($12,000 minus the $10,000 paid to the independent GM dealer), or if the customer paid off the RISC immediately the GM group made no profit (the $10,000 of stated principal minus the $10,000 paid to the independent GM dealer). The purpose of the consolidated return regulations is to provide rules so that the tax liability of a consolidated group will be clearly reflected and to prevent the avoidance of such tax liability. See sec. 1502. GM and GMAC have not fabricated a transaction where numbers merely are being shuffled on paper without any real loss to the GM group. The GM group's treatment of the rate support deductions and the discount income clearly reflected its tax liability. Based on the foregoing, we conclude that the discount income was not the corresponding item of income to the rate support deductions.Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
Last modified: May 25, 2011