- 31 - goods sold and the gross receipt from the sale, and respondent has not challenged that treatment. While he has misunderstood how petitioner accounted for the off-invoice discounts, we assume that respondent would agree that, as between petitioner and the vendors, any off-invoice discounts or deemed rebates were trade discounts, which reduced the cost to petitioner of merchandise purchased from the vendors. See sec. 1.471-3(b), Income Tax Regs. (cost of merchandise purchased during taxable year is invoice price less “trade” and certain other discounts); Rev. Rul. 84-41, 1984-1 C.B. 130, 130 (“Trade discounts represent adjustments to the purchase price granted by a vendor.”). Putting aside for the moment petitioner’s status as a cooperative corporation, it is difficult to see why the rebates that respondent deems petitioner received from vendors and passed on without alteration to member stores on sales made to those stores should not also be deemed to reduce petitioner’s receipts from those sales. We have found that the special show discounts were based on the quantity of merchandise member stores ordered from petitioner at the food shows. The discounts were an inducement to greater sales. If petitioner is deemed to have paid any show money, its purpose was to increase sales (and profits9) by reducing prices. Those deemed payments, 9 Petitioner ignored special show discounts in applying its markup to food show sales. See supra note 3.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: November 10, 2007