- 2 - 166.1 After concessions,2 we must determine whether $10 million of an $18 million debt became worthless in 1995. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the accompanying exhibits are incorporated by this reference. Petitioner’s principal place of business was Northlake, Illinois, at the time it filed the petition. The issue in this case arose as a management group attempted to respond quickly to a changing business environment in the bottling industry. As background, we explain the bottling industry in general and the economic environment in which it existed. Bottling Industry The soft drink bottling business around 1986 consisted of the "big three." There were two well-known titans, Coke and Pepsi, and a third quasi-independent network that encompassed all other beverages. Independent beverage labels at that time included drinks like Squirt, Dr. Pepper, 7-Up, Burns, and certain "new age" drinks. The independent bottling network was also 1All section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. 2The parties have resolved all other issues raised in the deficiency notice and the petition.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