- 7 - deficiency for the years in issue in which respondent disallowed the above claimed bad debt deductions to the extent the deductions claimed on the tax returns were based on delinquent loans with respect to which the automobiles securing the loans were repossessed or returned (or identified as unlocatable) after the end of the year for which, for Federal income tax purposes, the related bad debt deductions were claimed. The total amounts of petitioners’ claimed bad debt deductions disallowed by respondent for each year were allowed to petitioners by respondent as bad debt deductions for the immediately following year. Respondent also, in the notice of deficiency issued to ABC, disallowed the inventory write-downs claimed by ABC for its 1990 and 1992 tax years.2 In addition, respondent determined against petitioners accuracy-related penalties under section 6662(a). 2 Respondent’s notice of deficiency for 1990 issued to ABC also reflects a related sec. 481 adjustment that appears to be mechanical and not in dispute.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011