- 5 - With regard to delinquent loans with respect to which the automobiles securing the loans were not located by petitioners’ repossession agent, the entire outstanding balance of the loans would be charged off on petitioners’ corporate Federal income tax returns as business bad debt deductions.1 Whether a bad debt tax deduction relating to a particular loan and repossession was claimed on petitioners’ corporate Federal income tax return for the current tax year or for the prior tax year depended on when the loan originated and whether the repossession of the automobile occurred prior to the filing of the tax return for the prior tax year. With respect to a delinquent loan that had been made in the prior tax year and where the repossession of the automobile occurred in the current tax year but prior to the filing of the corporate Federal income tax return for the prior tax year, the related bad debt deduction would be claimed by petitioners on the tax return for the prior tax year. 1 The record is not completely clear as to how the amount of a particular loan chargeoff was calculated for purposes of petitioners’ financial books and records. Some evidence indicates that upon repossession or return of an automobile securing a loan, the amount of the chargeoff was calculated in the same manner as it was calculated for tax purposes (namely, all but $100 of the outstanding balance due on the related loan would be charged off). Other evidence indicates that for financial book purposes upon repossession of an automobile petitioners determined the wholesale book value of the automobile and charged off only the difference between the loan balance and the wholesale book value.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011