- 29 -                                         
               taxpayer, and whose denominator is the total of such                   
               amounts billed within the same five year period.  If                   
               the taxpayer has not been in existence for the prior                   
               five taxable years, the portion of such five year                      
               period which the taxpayer has been in existence is to                  
               be used.                                                               
                    For example, assume that an accrual-basis taxpayer                
               has $100,000 of receivables that have been created                     
               during the most recent five taxable years.  Of the                     
               $100,000 of accounts receivable, $1,000 have been                      
               determined to be uncollectible.  The amount, based on                  
               experience, which is not expected to be collected is                   
               equal to 1 percent ($1,000 divided by $100,000) of any                 
               receivable arising from the provision of services that                 
               are outstanding at close of the taxable year. [Emphasis                
               added; fn. ref. omitted.]                                              
               As the foregoing emphasized language reveals, one paragraph            
          of the committee report specifies that the Uncollectible Amount             
          is calculated by multiplying the total amount billed during the             
          taxable year by the ratio of the sum of the amount of those                 
          billings determined uncollectible within the most recent 5                  
          taxable years to the sum of the billings within that same 5-year            
          period.  In the example in the following paragraph, however, the            
          formula is expressed somewhat differently; to wit, in the                   
          example, the Uncollectible Amount is calculated by multiplying              
          the receivables outstanding at the close of the taxable year by             
          the ratio of the amount of those billings determined                        
          uncollectible within the most recent 5 taxable years to the sum             
          of the billings within that same 5-year period.  In our view, the           
          committee report merely suggests that Congress intended eligible            
          taxpayers to employ a method to determine statistically the                 
Page:  Previous   19   20   21   22   23   24   25   26   27   28   29   30   31   32   33   34   35   36   37   38   NextLast modified: May 25, 2011