- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011