As part of a warranty program provided by the manufacturer of graders, the taxpayer, which was a distributor, was required to inspect graders sold by it under the program twice per year for five years. Amounts paid by the manufacturer to the taxpayer only covered part of the cost of this inspection program.
The portion of the proceeds received on sale of graders that the taxpayer estimated represented the additional cost to it of the inspection program was eligible for a reserve on the basis claimed by the taxpayer, i.e., 4/5 of $5,000 per grader at the end of its first year - notwithstanding that in the subsequent year the taxpayer adjusted the reserve downward based on a review of its auditors that found the initial reserve to exceed actual costs.