Sika Chemical Corp. v. Commissioner
United States Tax Court
Petitioner, relying solely on balance sheet book value figures and consistent yearly losses, but without considering "going concern" values, charged off a portion of its subsidiary's debt as partially worthless under sec. 166(a)(2), I.R.C. 1954. Held, respondent's disallowance not shown to be arbitrary or unreasonable especially in view of fact that liquidation of the subsidary was not shown to have been contemplated nor to have occurred.
1Opinion of the Court
Forrester, Judge:
Respondent has determined the following deficiencies in petitioner’s Federal income taxes:
TYE Dee. 31— Deficiency
1964_ $11,378.01
1965_ 8,986.46
1966_ 60,504.08
1967_ 37,201.28
Because of a concession by petitioner, the only issue remaining for our decision is whether petitioner was entitled to bad debt loss treatment in 1967 for a part of certain advances made to its wholly owned Canadian subsidiary.
FINDINGS OF FACT
All of the facts have been stipulated and are so found.
Sika Chemical Corp. (petitioner), which was incorporated under the laws of the State of New Jersey, had its…
2Cases cited18 opinions
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