Legal Opinion

Time Acceptance, Inc. v. Commissioner

United States Tax Court

Decided April 8, 1985No. Docket Nos. 21190-82, 21191-82, 21192-82, 21193-82, 21194-82, 21195-82, 21196-82UnpublishedCited by 1 opinion

Ps were consumer finance corporations. The Commissioner redetermined Ps' allowable additions to their reserves for bad debts by use of the Black Motor formula. Held, Ps failed to prove that the Commissioner's determination of the allowable additions to their reserves was unreasonable.

1Opinion of the Court

TIME ACCEPTANCE, INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Time Acceptance, Inc. v. Commissioner

Docket Nos. 21190-82, 21191-82, 21192-82, 21193-82, 21194-82, 21195-82, 21196-82.

United States Tax Court

T.C. Memo 1985-173; 1985 Tax Ct. Memo LEXIS 455; 49 T.C.M. (CCH) 1186; T.C.M. (RIA) 85173;

April 8, 1985.

Ps were consumer finance corporations. The Commissioner redetermined Ps' allowable additions to their reserves for bad debts by use of the Black Motor formula. Held, Ps failed to prove that the Commissioner's determination of the allowable additions to their…

2Cases cited17 opinions

  1. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  2. Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
  3. Black Motor Co. v. CommissionerUnited States Board of Tax Appeals · 1940
  4. Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
  5. James A. Messer Co. v. CommissionerUnited States Tax Court · 1972

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3Cited by1 opinion

  1. Beneficial Corporation and Subsidiaries v. The United StatesCourt of Appeals for the Federal Circuit · 1987

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