- 7 - projected income of $50 million for K&H. K&H was not directly involved in the research and development of the vending machine. K&H determined the amount of partial worthlessness of the advances made to Snacks each year by comparing the prior year’s ending advance balance with Snacks’ cumulative losses to arrive at a ratio. The resulting ratio was then applied to the prior year’s ending advance balance to arrive at the claimed writeoff. Snacks’ net worth as of July 31, 1990, 1991, 1992, 1993, and 1994 was a negative $1,244,172, $2,107,158, $2,571,348, $3,019,739, and $3,126,138, respectively, each caused by an excess of liabilities over assets. For its fiscal years ended April 27, 1991, and April 25, 1992, K&H claimed that the advances to Snacks had become partially worthless (a bad debt) and deducted the amounts of $579,607 and $461,970, respectively. Respondent, in the notice of deficiency, determined that the claimed bad debt deductions were not allowable. K&H advanced Snacks more than $700,000 through April 1990 and additional amounts of $320,000 and $260,000 during the fiscal years ended April 1991 and 1992. For the period ended December 31, 1993, K&H, based on the accountant’s advice, sold to the accountant $650,000 of the notes for $1,000 in an attempt to “fix the time and amount of the loss.” Respondent determined that thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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