David J. Lychuk and Mary K. Lychuk, et al. - Page 84




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               expenditures included any postacquisition or servicing                 
               expenses. * * *                                                        
                    6We 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).                       
               [Majority op. p. 10; emphasis added.]                                  
               From the majority’s findings of fact I conclude:  (1) ACC’s            
          business operation consisted of the acquisition of installment              
          contracts and the postacquisition servicing of those contracts;             
          and (2) of the total expenses for salaries and overhead for 1993            
          and 1994, $267,832 for 1993 and $339,211 for 1994 were related to           
          credit analysis activities and were not related to any other                
          business operations of ACC.3  To me, the logical conclusion is              
          that both salaries and overhead expenses, totaling $267,832 for             
          1993 and $339,211 for 1994, were exclusively for ACC’s                      
          acquisition of installment contracts and thus were “directly”               
          related to the acquisition of installment contracts.                        
               The percentage of ACC’s salaries and “overhead” expenses               
          that related exclusively to ACC’s credit analysis activities                
          indicates that most of ACC’s business activity concerned the                
          acquisition of installment contracts.  For example, 76 percent of           
          salaries and 68 percent of “overhead” expenses for 1993 were                
          related to ACC’s credit analysis activities.  For 1994, the                 


               3The majority finds that “None of these expenditures                   
          included any postacquisition or servicing expenses.”  Majority              
          op. p. 10.  ACC’s only business operation was the acquiring of              
          installment contracts and the postacquisition servicing of those            
          installment contracts.                                                      




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