- 2 - FYE May 31 Deficiency 1989 $66,096 1990 663,532 1991 1,014,268 1992 752,581 Flint Industries, Inc., and subsidiaries, hereinafter collectively referred to as petitioner, filed a petition to redetermine the deficiencies.1 Following concessions, the issue presented for decision is whether the following worthless stock and bad debt deductions claimed by petitioner on its consolidated Federal income tax returns for fiscal years ending (FYE) May 31, 1992, 1993, and 1994, are allowable under sections 165 and 166:2 FYE May 31 Worthless stock Bad debt 1992 $7,374,438 $6,564,124 1993 2,435,876 815,105 1994 –- 6,085,248 Respondent contends that petitioner’s worthless stock and bad debt deductions must be disallowed because (1) the amounts claimed as bad debts were capital in nature, and (2) petitioner has failed to prove that the alleged bad debts and worthless 1Petitioner reported net operating losses (NOLs) for fiscal years ended 1992, 1993, and 1994 which it carried back to prior years. Respondent’s adjustments reduced the NOLs available to be carried back to prior years, resulting in the deficiencies determined by respondent in the notice of deficiency. 2All section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Monetary amounts have been rounded to the nearest dollar or deutsche mark as appropriate.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