Foster Frosty Foods, Inc. v. Commissioner of Internal Revenue

LEWIS, Circuit Judge.

This is a petition for review of a decision of the Tax Court holding that the determinative issue of the case was whether discounted notes could be considered as a factor in establishing a deduction for a reasonable addition to a reserve for bad debts under 26 U.S.C. § 166(c) and deciding that issue in ac cordance with the Commissioner’s determination that such discounted notes could not be so considered. The case reaches us after earlier review by the entire Tax Court, three judges dissenting, one judge concurring in the result, and three judges concurring specially upon…