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portion of a receivable. The statute on its face, furthermore,
provides no formula for calculating that amount. Petitioners,
however, in essence argue that, when the Code employs the word
"experience" in conjunction with bad debts, the word has a
predetermined meaning which prescribes the formula that must be
used to calculate the uncollectible portion of an amount owed a
taxpayer.
In that regard, petitioners contend that Congress explicitly
recognized that the term "experience" as it relates to bad debt
experience is synonymous with the Black Motor formula. We have
found no cases, and petitioners have cited none, where the term
"experience" was found to have the technical meaning advanced by
petitioners. Moreover, section 448 does not define the word in
that manner. In support of their contention petitioners cite
section 585(b)(2),11 which describes "the experience method" that
11 Sec. 585, as amended by sec. 11801(c)(12) of the Omnibus
Budget Reconciliation Act of 1990, Pub. L. 101-508, 104 Stat.
1388-527, provides in pertinent part as follows:
SEC. 585. RESERVES FOR LOSSES ON LOANS OF BANKS.
(a) Reserve for Bad Debts.--
(1) In general.--Except as provided in subsection
(c), a bank shall be allowed a deduction for a
reasonable addition to a reserve for bad debts. Such
deduction shall be in lieu of any deduction under
section 166(a).
* * * * * * *
(b) Addition to Reserves for Bad Debts.--
(continued...)
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