David J. Lychuk and Mary K. Lychuk, et al. - Page 3




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          corporation, Automotive Credit Corporation (ACC).  Respondent               
          determined a $1,202 deficiency in the 1993 Federal income tax of            
          David J. and Mary K. Lychuk.  Respondent determined $2,149 and              
          $11,461 deficiencies in the 1993 and 1994 Federal income taxes,             
          respectively, of Edward C. and Virginia M. Blasius.  Respondent             
          determined $23,683 and $89,609 deficiencies in the 1993 and 1994            
          Federal income taxes, respectively, of James E. and Mary Jo                 
          Blasius.2  Both Blasius couples alleged in their respective                 
          petitions that they had an overpayment for 1994 on account of               
          costs which ACC failed to deduct for that year.                             
               Following concessions, we must decide whether ACC must                 
          capitalize certain expenditures made during 1993 and 1994.  The             
          expenditures were generally ACC’s payment of (1) salaries,                  
          benefits, and overhead (printing, telephone, computer, rent, and            
          utilities) relating to its acquisition of retail installment                
          contracts (installment contracts) in the ordinary course of its             
          business (installment contracts expenditures) and (2)                       
          professional fees and commissions relating to a private placement           
          offering of notes that ACC accomplished in 1993 and a second                
          offering that ACC planned in 1993 and abandoned in 1994                     
          (collectively, PPM expenditures).  We hold that ACC must                    
          capitalize both groups of expenditures to the extent described              
          herein.  We must also decide whether ACC may deduct the portion             


               2 James Blasius is Edward Blasius’ son.                                





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