- 11 - year of inception of an EWA, plus the imputed income represented by the interest-equivalent factor in each of the years of the contract term. In the notices of deficiency, respondent determined that the service warranty income reported by petitioners had been computed incorrectly for the years in issue.7 Respondent contends that petitioners incorrectly computed their deduction for insurance costs in the year a policy was purchased by taking a full year’s worth of amortization rather than amortization measured from the actual date of the policy’s inception and payment of the premium. In the absence of information regarding the actual dates of sale of EWA’s, respondent recomputed petitioners’ amortization deductions on the assumption that the transactions had occurred ratably over the years in issue. In their petitions, petitioners alleged that respondent erred in recomputing the amortization deductions, contending that their amortization of insurance expense should be computed using the same methodology as that used in computing receipt of EWA income; that is, the convention deeming qualified advance payment amounts as having been received on the first day of the taxable year should likewise apply for amortization of insurance expense, 7 In the case of the Zamoras, the deficiency was determined on the basis of the Zamoras’ distributive share of comparable adjustments made to the warranty income of their S corporation, Wondries Chevrolet.Page: 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