Walter H. Goodrich & Co. v. Commissioner
United States Board of Tax Appeals
1. The disallowance of a deduction of part of an addition made by a taxpayer to a reserve for bad debts in respect of loans made to an affiliate, held not arbitrary or capricious when, during the taxable year the taxpayer continued to make advances and the affiliate had large and growing sales. 2. The stock of an affiliate which had large and growing sales and to which the taxpayer continued to make advances, held not to have become worthless during the taxable year.
1Opinion of the Court
*961OPINIOST.
Steknhagen :
The Commissioner disallowed the deduction of $60,-000 claimed on petitioner’s 1934 return as a “reasonable addition to a reserve for bad debts” (Revenue Act of 1934, sec. 23 (k)). In its original petition the petitioner still claimed the deduction as a bad debt reserve. By an amended petition it changed the claimed deduction to that of $20,000 addition to bad debt reserve by reason of the worthlessness of the Oil Products debt, and $40,000 loss sustained in its investment in Oil Products shares.
1. The deduction of a reasonable addition to a reserve for bad debts is…
2Cited by13 opinions
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1965
- Ardela, Inc. v. CommissionerUnited States Tax Court · 1969
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1965
- Funkhouser Industries, Inc. v. CommissionerUnited States Tax Court · 1957
- H. Wolff Book Mfg. Co., Inc. v. CommissionerUnited States Tax Court · 1950
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