- 32 - 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.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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