- 9 - See Rev. Proc. 92-98, secs. 9, 4.04, 1992-2 C.B. at 517, 513. With respect to accounting for insurance costs, Rev. Proc. 92-97, supra, provides that lump-sum amounts, paid in advance for multiyear insurance policies to insure a consumer durable goods seller’s obligations to customers under multiyear warranty contracts sold to them, must be capitalized and prorated or amortized over the life of the insurance policy. See Rev. Proc. 92-97, sec. 2.07, 1992-2 C.B. at 511. During the years at issue, in accordance with Rev. Proc. 92- 98, supra, petitioners reported as income in the year of receipt the difference between the total amount received from the sale of EWA’s and the total amount paid to Western General. The remaining proceeds from the sale of EWA’s--i.e., the amounts paid to Western General to insure petitioners’ risks under the EWA’s, or qualified advance payment amounts--were, as increased by an interest-equivalent factor, included in income ratably over the terms of the EWA’s. Pursuant to Rev. Proc. 92-98, supra, for purposes of computing the income required to be included each year in connection with the qualified advance payment amount, petitioners treated the proceeds from the sale of EWA’s as having been received on the first day of the taxable year in which an EWA was sold. Petitioners took deductions for the amounts paid to Western General for assumption of the EWA liabilities by capitalizingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011