General Motors Corporation and Subsidiaries - Page 56

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               Based on the foregoing, we conclude that the discount income            
          was not earned in an intercompany transaction.                               
               C.  Conclusion                                                          
               We conclude that under the 1966 regulations, the discount               
          income GMAC earned over the term of RISC's/fleet loans from                  
          retail/fleet customers was not the corresponding item of income              
          in an intercompany transaction to the rate support deductions.               
          Therefore, the GM group was not required to defer the rate                   
          support deductions on its consolidated income tax return.                    
               To reflect the foregoing,                                               
                                                   An appropriate order                
                                              will be issued.                          

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