- 8 - 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 inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011