Foretravel, Inc. - Page 32

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            inventory.  Thus, petitioner could reasonably expect to see                                    
            losses surface during this market slowdown.   After learning                                   
            about Northwest's financial setbacks, Franklin and Wilcox                                      
            traveled to Coeur d'Alene, Idaho, to assess the situation at                                   
            Northwest.  After observing some of the fundamental problems at                                
            Northwest, Wilcox returned to Northwest in November 1988 and                                   
            placed supervisory and financial controls on Northwest's                                       
            operations.  Petitioner obtained additional collateral from                                    
            Nicholson, patent rights, and his Northwest stock, and petitioner                              
            sent Clark to Coeur d'Alene so that she could manage the business                              
            side of Northwest.                                                                             
                  We find petitioner's response reasonable especially in light                             
            of the fact that petitioner exerted no management or financial                                 
            controls over Northwest prior to the fall of 1988.  Petitioner's                               
            officers decided to assist a dealership that provided an outlet                                
            for petitioner's products in a profitable region.  Petitioner                                  
            provided loans to Northwest and applied financial and management                               
            controls over Northwest's operations when additional problems                                  
            surfaced.  Petitioner engaged Axley & Rode for advice and                                      
            assistance in evaluating Northwest's financial condition.  Given                               
            Northwest's success prior to the market slowdown in the spring of                              
            1988, petitioner reasonably could conclude that Northwest would                                
            be able to pay the amounts advanced.  See Baldwin v.                                           
            Commissioner, T.C. Memo. 1993-433.  Petitioner properly deducted                               
            the disputed amounts as bad debts.                                                             




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