T.C. Memo. 2001-220
UNITED STATES TAX COURT
BRAZORIA COUNTY STEWART FOOD MARKETS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1037-99. Filed August 14, 2001.
George W. Connelly, Jr., and William O. Grimsinger, for
petitioner.
Richard T. Cummings, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined deficiencies in
petitioner’s Federal income tax for its fiscal tax years ended
September 30, 1991, 1992, and 1994, of $216,552, $225,336, and
$8,190, respectively. The sole issue for our consideration is
whether bad-debt deductions taken in 1994 are allowable under
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