David J. Lychuk and Mary K. Lychuk, et al. - Page 10




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          of principal and/or would finance the purchase over a shorter               
          repayment term.                                                             
               In 1993 and 1994, ACC paid installment contracts                       
          expenditures totaling $267,832 and $339,211, respectively.  These           
          expenditures, which were attributable to ACC’s obtaining of                 
          credit reports and screening of credit histories, related                   
          primarily to the portion of ACC’s payroll and overhead expenses             
          that was attributable to its credit analysis activities.6  None             
          of these expenditures included any postacquisition or servicing             
          expenses.  ACC ascertained the amount of these expenditures at              
          the request of its independent auditors.  The parties agree that            
          these expenditures are “related” to ACC’s credit analysis                   
          activities and that the breakdown of specific expenditures is as            
          set forth below.  The parties dispute whether any or all of the             
          expenditures is “directly related” to ACC’s credit analysis                 
          activities, as contended by respondent, or is “indirectly                   
          related” to those activities, as contended by petitioners.                  










               6 We use the term “credit analysis activities” to refer to             
          ACC’s credit review services and its funding services (i.e.,                
          ACC’s issuance of the checks to dealers in consideration for the            
          installment contracts).                                                     




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