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They assert that the Black Motor formula was merely a tool for
determining a taxpayer's bad debt experience and was not
mandatory for all circumstances. Petitioners contend that, to
correctly apply the Black Motor formula, the regulations should
allow modifications or departures for particular facts and
circumstances. The foregoing arguments indicate that petitioners
use the term "Black Motor formula" to mean the reserve method of
accounting for bad debts that was in effect prior to repeal of
section 166(c) as well as the mathematical formula specified in
the case from which the method derives it name. See Black Motor
Co. v. Commissioner, 41 B.T.A. 300, 302 (1940), affd. on another
issue 125 F.2d 977 (6th Cir. 1942).
As we view their position, petitioners essentially would
prefer to substitute for the nonaccrual-experience method
provided by Congress the reserve method of accounting for bad
debts that was in effect prior to repeal of section 166(c)
whereby the addition to the bad debt reserve was based on a
reasonable amount determined by the taxpayer, with the
reasonableness of that addition tested generally under the Black
Motor formula. See Thor Power Tool Co. v. Commissioner, 439 U.S.
522, 546 (1979); Black Motor Co. v. Commissioner, supra. That
result, however, is not consistent with the statute. Nothing in
the statute or the legislative history requires the Uncollectible
Amount to equal the amount that would have been calculated
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