Clinton N. and Naomi K. Bohannon - Page 15

                                                  15                                                    
                        a.    Journal Entry No. 2                                                       
                  Respondent contends that journal entry No. 2 is incorrect.                            
            Journal entry No. 2 increased the cost of new cars by $10,000 and                           
            used cars by $21,789 and credited the allowance for doubtful                                
            accounts (a "contra account”)2 by $31,789.  Respondent argues                               
            that petitioners have not shown that these amounts were correct.                            
            Respondent contends that amounts in the contra account had                                  
            already reduced income, and that reducing this account at yearend                           
            resulted in a double reduction of income.  Respondent contends                              
            that this adjustment should have been made for 1987, not 1988.                              
            We disagree.                                                                                
                  Kane made journal entry No. 2 to correct an entry                                     
            erroneously made by the dealership's bookkeeper to a nonexistent                            
            account called "allowance for doubtful accounts".  The bookkeeper                           
            should have made the entry to the expense account.  Journal entry                           
            No. 2 corrected this error.  It did not affect the dealership's                             
            taxable income.                                                                             
                  Respondent has offered no support for the contention that                             
            journal entry No. 2 should have been made in 1987.  Bob Wade Ford                           



                  2 A contra account is the functional equivalent of a reserve                          
            for a bad debt.  See Thor Power Tool Co. v. Commissioner, 64 T.C.                           
            154, 156 (1975), affd. 563 F.2d 861 (7th Cir. 1977), affd. 439                              
            U.S. 522 (1979); Hutton v. Commissioner, 53 T.C. 37, 39 (1969).                             







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