ABC Beverage Corp., f.k.a. Beverage America, Inc. - Page 23

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               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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