Revenue Ruling 76-96

1976-1 C.B. 23 (1976)

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Revenue Ruling 76-96

Internal Revenue Service
1976-1 C.B. 23 (1976)

Facts

An automobile manufacturer instituted a rebate program in which the manufacturer paid a $40x rebate to qualifying retail customers who purchased or leased a certain type of new automobile within a prescribed period of time. To qualify for the rebate, the customer had to independently negotiate a sale or lease price at arm’s length with one of the manufacturer’s dealers. The rebate was made to the customer after the delivery of the automobile. The Internal Revenue Service issued a revenue ruling to clarify whether the manufacturer’s rebates were includible in customers’ gross incomes.

Rule of Law

Issue

Holding and Reasoning ()

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