Best Auto Sales, Inc. - Page 6




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               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 after 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 current tax year.                                        
               For example, for the tax year ending May 31, 1990,                     
          petitioner ABC Autos, Inc. (ABC), in November of 1990 (before               
          filing its corporate Federal income tax return for its tax year             
          ending May 31, 1990), charged off as bad debts $237,795 in                  
          automobile loans that were outstanding as of May 31, 1990, even             
          though the automobiles securing the loans were repossessed                  
          between June and November of 1990.  In ABC’s journal entry of               
          November 17, 1990, reflecting the above chargeoff of $237,795, a            
          written notation is made to the effect that the related loans               
          “went bad in June-Nov. ‘90’”.                                               
               Also, on ABC’s corporate Federal income tax returns for its            
          tax years ending May 31, 1990 and 1992, ABC’s yearend total basis           
          in its used automobile inventory was written down under sections            
          1.471-2(c) and 1.471-4(c), Income Tax Regs.  No records were                
          maintained by ABC to substantiate how these inventory write-downs           
          were calculated.                                                            
               After respondent’s audits were completed, on February 28,              
          1997, respondent issued to each petitioner a separate notice of             






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