Load, Inc. - Page 9

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               The independent salespersons do not receive wages, salary,             
          sales commissions, or other fees or incentives from ADI or from             
          the manufacturers or lenders relating to manufactured homes that            
          are sold.  Rather, for their income the independent salespersons            
          retain 100 percent of the retail price markup from the                      
          manufacturer’s wholesale price.                                             
               In the written agreements ADI enters into with the                     
          independent salespersons, the independent salespersons expressly            
          give up their right to receive any of the manufacturers’ retail             
          incentive payments and acknowledge that ADI is to receive all               
          incentive payments.                                                         
               On petitioners’ timely filed corporate Federal income tax              
          returns for their tax year ending September 30, 2000, petitioners           
          deducted, among other things, as section 162 ordinary and                   
          necessary business expenses $243,350 in sales lot lease payments            
          and $22,387 in miscellaneous expenses incurred during the year.             
          The $22,387 miscellaneous expenses consist of $16,184 ADI paid to           
          ship model manufactured homes from closed sales lots to other               
          sales lots, $3,423 ADI paid to avoid a sheriff’s seizure relating           
          to delinquent State taxes a former independent salesperson had              
          not paid, $2,500 ADI paid for repairs on a model manufactured               
          home, and $280 ADI paid for cleaning a water-damaged carpet in a            
          model manufactured home.                                                    








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Last modified: May 25, 2011