Load, Inc. - Page 2

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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