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Conclusion
Petitioner may deduct $10 million as a worthless debt in
1995. The Properties loan was partially worthless in 1995
because identifiable events occurred during that year that made
it certain that Properties would be unable to repay it.
Respondent’s determination to the contrary was unreasonable and
an abuse of discretion. Although petitioner’s predecessor,
Bottlers, may have contributed to the worthlessness of the
Properties loan, this action does not preclude petitioner from a
bad debt deduction where other major business factors contributed
to the worthlessness.
In reaching our holding, we have considered all arguments
made, and, to the extent not mentioned, we conclude that they are
moot, irrelevant, or without merit.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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