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JOHNSON v. C.I.R.

No. 98-1324.

184 F.3d 786 (1999)

Rameau A. JOHNSON; Phyllis A. Johnson; Thomas R. Herring; Karon S. Herring; DFM Investment Company; David F. Mungenast; and Barbara J. Mungenast, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: July 21, 1999.

Attorney(s) appearing for the Case

Richard M. Lipton, Chicago, IL, argued, for Appellants.

Joan I. Oppenheimer, Washington, DC, argued, for Appellee.

Before: RICHARD S. ARNOLD and WOLLMAN, Circuit Judges, and MAGNUSON, District Judge.

RICHARD S. ARNOLD, Circuit Judge.

This case involves the appropriate method of accounting for income received on the sale of vehicle service contracts (VSCs) by four motor-vehicle dealerships. We will summarize such of the undisputed facts as are necessary to an understanding of the issue. When a car is sold, the dealerships also offer for sale a VSC. This is a kind of warranty agreement, under which the dealership grants to the buyer the right to have parts or components...

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