Toyota Town, Inc. - Page 3




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               These cases were consolidated for trial, briefing, and                 
          opinion.2  Petitioners include the following corporations:                  
          Toyota Town, Inc.; Country Nissan, A California Corporation;                
          Quality Motor Cars of Stockton, A California Corporation; Bob               
          Wondries Motors, Inc., d.b.a. Wondries Ford; Wondries Nissan,               
          Inc.; and Bob Wondries Associates, Inc., d.b.a. Wondries Toyota;            
          as well as individual petitioners Robert S. and Christina Zamora            
          (Zamoras), who filed joint returns for the years in issue.  The             
          Zamoras owned, during the years in issue, approximately 48                  
          percent of the issued and outstanding shares of Wondries                    
          Chevrolet, Inc. (Wondries Chevrolet), an S corporation within the           
          meaning of section 1361(a).3  For convenience, we shall                     
          hereinafter refer to Wondries Chevrolet and the C-corporation               
          petitioners collectively as petitioners.                                    
               The issue for decision is the proper period for petitioners            
          to deduct insurance premium expense incurred in connection with             
          sales of extended warranty agreements to their customers.                   



               2 In docket No. 4959-95, the adjustment relating to the 1991           
          taxable year is not in dispute.  In docket No. 4960-95 only the             
          adjustments relating to the 1992 and 1993 taxable years have been           
          consolidated, and the adjustment relating to the 1991 taxable               
          year is not in dispute.  In the remaining docket Nos., 4961-95,             
          22741-95, 1254-96, 1255-96, and 1256-96, all adjustments are                
          attributable to the common issue in dispute.                                
               3 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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