Brooks v. Commissioner
United States Tax Court
A corporation, of which petitioners were transferees, used the reserve method authorized by sec. 166(c), I.R.C. 1954, in computing its bad debt deductions. In August 1969, the corporation sold its assets and liquidated. For each prior year, the corporation had deducted as an addition to its bad debt reserve the amount of its accounts receivable referred to an attorney or agency for collection.
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A corporation, of which petitioners were transferees, used the reserve method authorized by sec. 166(c), I.R.C. 1954, in computing its bad debt deductions. In August 1969, the corporation sold its assets and liquidated. For each prior year, the corporation had deducted as an addition to its bad debt reserve the amount of its accounts receivable referred to an attorney or agency for collection. For its taxable year ended June 30, 1969, it claimed a further addition measured by the discount given the purchaser of its accounts receivable on the sale of its assets. Held, the corporation is not…
1Opinion of the Court
Harold F. Brooks, Petitioner v. Commissioner of Internal Revenue, Respondent; Hanna A. Brooks, Petitioner v. Commissioner of Internal Revenue, Respondent
Brooks v. Commissioner
Docket Nos. 1705-73, 1706-73
United States Tax Court
63 T.C. 1; 1974 U.S. Tax Ct. LEXIS 38;
October 1, 1974, Filed
Decisions will be entered for the respondent.
A corporation, of which petitioners were transferees, used the reserve method authorized by sec. 166(c), I.R.C. 1954, in computing its bad debt deductions. In August 1969, the corporation sold its assets and liquidated. For each prior year, the corporation had…
2Cases cited10 opinions
- Nash v. United StatesSupreme Court of the United States · 1970
- Roanoke Vending Exchange, Inc. v. CommissionerUnited States Tax Court · 1963
- Platt Trailer Co. v. CommissionerUnited States Tax Court · 1955
- Consolidated-Hammer Dry Plate & Film Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1963
- Bird Management, Inc. v. CommissionerUnited States Tax Court · 1967
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