- 2 - are to the Tax Court Rules of Practice and Procedure, unless otherwise specified. Following a concession by petitioner,1 the only issue for decision is whether petitioner is entitled to a section 166 "bad debt" deduction for funds it advanced to one of its construction superintendents, who is also the son of its president and controlling shareholder. Petitioner deducted the full amount of these advances remaining unpaid (plus accrued "interest") on the return for its tax year ending July 31, 1992. Respondent denied this deduction in its entirety. The deficiency still disputed for petitioner's tax year ending July 31, 1993, is a computational adjustment arising from a reduced carryforward that would result if we should sustain respondent's disallowance of the bad debt deduction for 1992. FINDINGS OF FACT Some of the facts have been stipulated and are so found; the stipulation of facts and related exhibits are incorporated by this reference. Petitioner's principal place of business was Redmond, Oregon, when it filed the petition. Petitioner uses the accrual method of accounting for Federal income tax purposes. 1 Petitioner has conceded a $12,805 "shareholder expenses" deduction claimed for the tax year ended July 31, 1992.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011