id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-29046	W. Swain, Andrew	Recent Developments in Indiana Tax Case Law: Survey 2024	2025	46	.pdf	application/pdf	20590	1060	55	[Vol. 58:923 958 affiliate, Indiana Finance, purchased these contracts without recourse355 for 65% or 70% of the original amount financed.356 That is, it purchased the installment contracts at a 35% or 30% discount on their face values.357 After several customers defaulted on their contracts, Indiana Finance repossessed and sold the vehicles at auction or directly back to Oak Motors.358 Indiana Finance determined the fair market value of repossessed vehicles sold at auction using the auction proceeds, and used the Manheim Market Report (“MMR”)359 to establish the fair market value of vehicles sold to Oak Motors.360 Indiana Finance also collected third-party insurance and warranty claim payments for some repossessed vehicles.361 Pursuant to Internal Revenue Code (“IRC”) section 166’s bad-debt deduction rules, and for federal and Indiana income tax purposes, Indiana Finance claimed bad-debt deductions on these defaulted contracts for the 2017 and 2018 tax years.362 It also sought a refund for the sales taxes Oak Motors had remitted to the Department, which became uncollectable receivables following the customer defaults.363 Indiana Finance asserted that its bad-debt calculations comported with Indiana Tax Court precedent.364 Indiana Finance applied the Market Discount Rules under IRC sections 1276 through 1278 “to the value of repossessed vehicles, insurance claim payments, and warranty claim payments. L. REV. 979, 1010 (June 2024) (discussing the appointment of the new Indiana Tax Court judge, Justin L. McAdam).	cache/inlawrev-29046.pdf	txt/inlawrev-29046.txt