Mann Construction Co., Inc. - Page 2




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          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.                     




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