- 46 - the orders placed by the member stores at the food shows. They reduce petitioner’s gross receipts and are not defective patronage dividends.12 C. Conclusion For the audit years, petitioner had no items of gross income on account of petitioner-delivered currency paid by vendors to member stores as show money. IV. Conclusion In the light of the foregoing, Decision will be entered for petitioner. 12 Our conclusion is, of course, based on the assumption that the petitioner-delivered currency paid to member stores flowed through petitioner, as passed-on rebates, in the manner described supra in sec. III.B.1 of this report. We do not decide that manufacturers’ rebates paid directly to retail customers are necessarily deemed to pass through the retailer. Such a rebate was addressed by the Commissioner in Rev. Rul. 76-96, 1976-1 C.B. 23, suspended in part by Rev. Rul. 2005-28, 2005-1 C.B. 997, which describes an automobile manufacturer’s rebate paid directly to qualifying retail customers and gives no indication that the rebate was considered to have flowed through the retailer.Page: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46Last modified: November 10, 2007