- 16 - 1985 through 1993, petitioner included taxable income of $5,636,762, $16,627,101, $2,035,928, $2,601,628, $3,213,184, $3,563,858, $3,569,015, $3,569,015, and $3,569,015, respectively. The adjustments in dispute in the 1985-90 taxable years are the net differences between the amounts of nonrefundable commitment fees received and reported for tax purposes, as follows: Nonrefundable Amount in Commitment Fees Received Reported Dispute 1985-90 1985 $9,506,398 $5,636,762 $3,869,636 1986 16,489,524 16,627,101 (137,577) 1987 9,408,907 2,035,928 7,372,979 1988 4,525,606 2,601,628 1,923,978 1989 4,892,445 3,213,184 1,679,261 1990 2,805,392 3,563,858 (758,466) In computing its taxable income for the year 1985, petitioner overstated its income attributable to such receipts under its method of accounting in the amount of $883,638 as a result of a computational error. During the years 1985 through 1988, and 1990, originators failed to deliver at least 67 mortgages specified in prior approval purchase contracts to petitioner.15 See appendix, which lists these 67 contracts. As a result, the 1.5-percent refundable portion of the 2-percent commitment fee was forfeited to petitioner. During the relevant period, these 67 contracts 15 Petitioner was unable to locate records of the prior approval purchase contracts executed in 1989 that would identify the mortgages from that year, if any, where the specified mortgages were undelivered.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011