-15-
Accordingly, we conclude that petitioner's dominant
motivation in making the loan to Tag Coal was to protect J & M's
equipment and ultimately petitioner's ability to lease such
equipment to third parties. We therefore hold that the debt owed
to petitioner by Tag Coal is appropriately characterized as a
business bad debt and is deductible by petitioners as such.
In order to reflect our disposition of the disputed issues,
as well as the parties' concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011