Nissan Motor Co. failed to declare some ¥64 billion in income in the three years to March 2007 in connection with its group realignment, sources said Wednesday.

The automaker appears to have appealed the Tokyo Regional Taxation Bureau's order to pay back taxes, including penalties, which are believed to total several billion yen, the sources said.

The bureau has determined that Nissan gained profits from a capital increase related to a realignment of its group's sales network aimed at unifying the management of assets at its sales subsidiaries nationwide, the sources said.

Under the realignment, Nissan split 52 sales subsidiaries into asset management firms and sales companies in April 2006. In July that year, Nissan's wholly owned subsidiary, Nissan Network Holdings Co., acquired the asset management firms, while obtaining shares in the sales companies.

Because many of the asset management firms were running into capital deficits at the time of the realignment, Nissan took such steps as increasing capital and carrying out debt-for-equity swaps, according to the sources.

The bureau has judged that Nissan Network failed to declare profits gained from increasing capital as the excessive liabilities of the asset management firms had been dissolved before Nissan Network absorbed the firms, the sources said.