James E. Blasius and Mary Jo Blasius, et al. - Page 8

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          of ACC’s (1) loan origination/acquisition costs and (2)                     
          professional fees.                                                          
          Nature of the Expenses Conceded by Respondent To Be Deductible in           
          the Year Incurred                                                           
               Loan Origination/Acquisition Costs                                     
               ACC is the same S corporation that was the focus of our                
          report in Lychuk v. Commissioner, 116 T.C. 374 (2001), which                
          dealt with the 1993 and 1994 tax years of its then shareholders             
          (including petitioners James E. and Mary Jo Blasius).  In Lychuk            
          v. Commissioner, supra at 376, we reported certain basic facts              
          with respect to ACC:                                                        
               It was formed to provide alternate financing for                       
               purchasers of used automobiles or light trucks                         
               (collectively, automobiles) who have marginal credit.                  
               Its sole business operation is (1) the acquisition of                  
               installment contracts from automobile dealers (dealers)                
               who have sold automobiles to high credit risk                          
               individuals and (2) the servicing of those contracts.                  
               Its primary business activities are credit                             
               investigation, credit evaluation, documentation, and                   
               the monitoring of collections on installment contracts.                
               * * *                                                                  
          We have no reason to believe that those reported facts have                 
          changed.                                                                    
               Moreover, the parties appear to agree that the loan                    
          origination/acquisition costs are essentially identical in nature           
          to costs described in Lychuk v. Commissioner, supra at 377-381,             
          as incurred by ACC in investigating and acquiring automobile                
          dealer installment contracts with purchasers of automobiles.                
          Briefly, the costs at issue were incurred by ACC employees in               





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