Best Auto Sales, Inc. - Page 7




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          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.                                              






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Last modified: May 25, 2011