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amortized the installment contracts expenditures of $339,211 over
the expected lives of the related installment contracts for 1994.
ACC performed its credit review services as to approximately
1,824 credit applications in 1993 and approximately 2,158 credit
applications in 1994. As to those applications, ACC acquired 693
installment contracts in 1993 and 820 installment contracts in
1994; in other words, ACC acquired in each year approximately 38
percent of the installment contracts which were offered to it.
The original terms of the 1993 installment contracts averaged
23.89 months, and their actual duration averaged 17.5 months.
The original terms of the 1994 installment contracts averaged 29
months, and their actual duration averaged 19.5 months. Of the
693 installment contracts acquired in 1993, 182 had an actual
duration of 12 months or less. Of the 820 installment contracts
acquired in 1994, 217 had an actual duration of 12 months or
less.
ACC issued a private placement memorandum (PPM) on April 30,
1993, offering up to $2.4 million of its subordinated asset
7(...continued)
paid or less any fees received. * * * All other costs incurred
in connection with acquiring purchased loans or committing to
purchase loans shall be charged to expense as incurred.” We note
in passing, however, that rules such as SFAS 91 which are
compulsory for financial accounting purposes do not control the
proper characterization of an item for Federal income tax
purposes. See Thor Power Tool Co. v. Commissioner, 439 U.S. 522,
542-543 (1979); see also Old Colony R.R. Co. v. Commissioner, 284
U.S. 552, 562 (1932).
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