David J. Lychuk and Mary K. Lychuk, et al. - Page 15




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          $288,911 of the $339,211 in installment contracts expenditures on           
          its 1994 Federal income tax return.  ACC now claims that it was             
          entitled to deduct for 1994 the remaining $50,300 of installment            
          contracts expenditures ($339,211 - $288,911).  As to the                    
          respective years, ACC deducted officers’ compensation of $158,099           
          and $217,036 and salaries/wages of $126,464 and $194,306.  The              
          portion of the officers’ compensation, salaries/wages, and                  
          overhead which was deducted but not in issue is attributable to             
          ACC’s servicing of the installment contracts.                               
               For financial accounting purposes, ACC separately listed the           
          installment contracts as assets on its 1993 and 1994 balance                
          sheets.  In addition, ACC initially deducted the installment                
          contracts expenditures of $267,832 for 1993 but amended that                
          year’s financial statements to amortize the expenditures over the           
          expected life of the related installment contracts.  ACC’s                  
          independent auditors required the amendment and related                     
          amortization in order to comply with Statement of Financial                 
          Accounting Standards No. 91 (SFAS 91), Accounting for                       
          Nonrefundable Fees and Costs Associated with Originating or                 
          Acquiring Loans and Initial Direct Costs of Leases.7  ACC                   


               7 The record does not indicate why ACC’s auditors believed             
          that the amendment was required under SFAS 91.  Whereas SFAS 91             
          provides explicitly for the deferral of “direct loan origination            
          costs”, it does not provide similarly as to the direct costs of             
          acquiring loans.  SFAS 91 provides as to the acquisition of loans           
          that “15.  The initial investment in a purchased loan or group of           
          loans shall include the amount paid to the seller plus any fees             
                                                             (continued...)           




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