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qualified banks use to determine the maximum amount they may add
to their reserves for bad debts. Petitioners assert, and
respondent does not dispute, that the experience method described
in section 585(b)(2) and section 1.585-2(c)(1), Income Tax Regs.,
is identical to the Black Motor formula.
Petitioners seemingly would have us conclude from the
foregoing that the word "experience" in section 448(d)(5) has the
same meaning as the term "experience method" in section 585. We,
however, do not agree that Congress' use of the word "experience"
in section 448(d)(5) necessarily shows congressional intent that
the Uncollectible Amount be calculated under the Black Motor
formula. Indeed, we think that it is more probable that, if
Congress had intended the same formula to apply in section
448(d)(5) and in section 585, then it would have specified that
the Uncollectible Amount be based on "the experience method" or
on "the Black Motor formula". The use of the word "experience"
in section 448(d)(5) and the words "experience method" in section
585 may reasonably be viewed as an indication of two different
meanings. Cf. Norfolk S. Corp. v. Commissioner, 104 T.C. 13, 38-
41 (1995).
In sum, we do not find that the statutory language manifests
congressional intent as to what method is to be employed to
calculate the Uncollectible Amount, and we conclude that section
11 (...continued)
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