- 21 -
22 B.T.A. 140 (1931); Martin v. Commissioner, 52 T.C. 140, 143
(1969), affd. per curiam 424 F.2d 1368 (9th Cir. 1970); Rietzke
v. Commissioner, 40 T.C. 443, 451 (1963); Bradford v.
Commissioner, 22 T.C. 1057, 1069 (1954), revd. on other issues
233 F.2d 935 (6th Cir. 1956); Standard Oil Co. v. Commissioner, 7
T.C. 1310, 1323 (1946), supplemented by 11 T.C. 843 (1948).
Petitioner appears to acknowledge in this case that
Intergraph had implied rights of subrogation and reimbursement
under the Guaranty Agreement. We agree. Intergraph's control of
Nihon Intergraph, if nothing else, would appear to provide
implied rights of subrogation against and reimbursement from
Nihon Intergraph.
Because it has not been established that Intergraph's rights
of subrogation and reimbursement from Nihon were worthless in
1987, Intergraph is not entitled to the claimed bad debt
deduction under section 166.
Decision will be entered
for respondent.
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