Auto Dealerships - Audit Technique Guide - Uncle Fed's Tax*Board
Auto Dealerships - Audit Technique Guide - Uncle Fed's Tax*Board Auto Dealerships - Audit Technique Guide - Uncle Fed's Tax*Board
For further information, refer to the Intangibles Settlement Initiative, the IRS National Office publication (March 29, 1994), known as "the Greenbook," which discusses the handling of Covenants Not To Compete. 15-5
This page intentionally left blank.
- Page 81 and 82: This page intentionally left blank.
- Page 83 and 84: Specific Identification Increment M
- Page 85 and 86: which may be identified by a unique
- Page 87 and 88: Step # 3 For each item category, ad
- Page 89 and 90: Step # 10 Compute the total cost of
- Page 91 and 92: 1991 Inventory Value at Current Yea
- Page 93 and 94: This page intentionally left blank.
- Page 95 and 96: Dealers may offer the contracts as
- Page 97 and 98: This page intentionally left blank.
- Page 99 and 100: 2. Principal/Obligor A principal is
- Page 101 and 102: Rev. Proc. 97-38 provided for an al
- Page 103 and 104: Contract Construction Generally, a
- Page 105 and 106: Rev. Proc. 97-27 provides the admin
- Page 107 and 108: The Court ruled that when the deale
- Page 109 and 110: Considerations for Forming a Produc
- Page 111 and 112: The Reinsurance Transaction To illu
- Page 113 and 114: insurance contract reinsured throug
- Page 115 and 116: (1979). The Service’s position is
- Page 117 and 118: While not all captive situations in
- Page 119 and 120: 3. IRC section 845 tax avoidance 4.
- Page 121 and 122: section, seemingly compliant arrang
- Page 123 and 124: 2. By owner A dealer may own dealer
- Page 125 and 126: Rules and Regulations Many rules re
- Page 127 and 128: This page intentionally left blank.
- Page 129 and 130: One of the assets specifically iden
- Page 131: Where a covenant may be enforced it
- Page 135 and 136: 1. Spread income over a number of y
- Page 137 and 138: RELATED FINANCE COMPANY CHECKSHEET
- Page 139 and 140: This page intentionally left blank.
- Page 141 and 142: 3. Question the taxpayer directly w
- Page 143 and 144: This page intentionally left blank.
- Page 145 and 146: Technicalities Under the provisions
- Page 147 and 148: This page intentionally left blank.
- Page 149 and 150: Cash 300 Accounts Receivable 300 2.
- Page 151 and 152: The dealer sells the note to a fina
- Page 153 and 154: For purposes of this rule, an "empl
- Page 155 and 156: 10) relationship of stockholder-off
- Page 157 and 158: purely for services. See Treas. Reg
- Page 159 and 160: Howard Sole, Inc. v. Commissioner,
- Page 161 and 162: Milford Motor Co. v. United States,
- Page 163 and 164: new pool for additional, subsequent
- Page 165 and 166: 6. The finance company is entitled
- Page 167 and 168: when the back-end distributions are
- Page 169 and 170: The transfer of the installment con
- Page 171 and 172: Report as a Loan or an Assignment
- Page 173 and 174: Reported as a Sale… (How it Shoul
- Page 175 and 176: Other Sources of Information IRC se
- Page 177 and 178: Part 4 Appendices Appendix A Initia
- Page 179 and 180: 2) Adjusting Journal Entries 3) Tax
- Page 181 and 182: k. Do you receive rebates from anyo
For further information, refer to the Intangibles Settlement Initiative, the IRS National Office<br />
publication (March 29, 1994), known as "the Greenbook," which discusses the handling of<br />
Covenants Not To Compete.<br />
15-5