Toyota Town, Inc. - Page 9




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          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 capitalizing               






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