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Petitioner Deficiency
LOAD, Inc. $16,589
COAD, Inc. $23,954
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
The issue for decision is whether certain costs relating to
manufactured homes that petitioners owned and placed on retail
sales lots in order to assist local independent salespersons in
the sale of manufactured homes may be currently deducted under
section 162 as ordinary and necessary business expenses or
whether they should be included under section 263A in
petitioners’ inventory costs relating to the manufactured homes.
Petitioners and 18 other related corporations are either
subsidiaries of, or sister corporations to, Associated Dealers,
Inc. (ADI), a Nevada corporation.
ADI and 12 of ADI’s related corporations also have filed
petitions with the Court relating to the same expense versus
inventory issue that is involved herein,1 and respondent, ADI,
and the other related petitioners have agreed to be bound by the
final outcome of this issue in these two consolidated cases.
1 The related docket numbers are: 7283-02, 7284-02, 7285-
02, 7286-02, 7288-02, 7289-02, 7290-02, 7291-02, 7292-02,
7293-02, 7295-02, 7296-02, and 7297-02.
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Last modified: May 25, 2011