Calavo, Inc. v. Commissioner
United States Tax Court
Held, that since it has not been shown that a certain debt owing to Calavo, Inc. became worthless during the year in question, the amount of such debt may not be charged against the reserve for bad debts and thereby be reflected in the computation of the deductible addition to the reserve for bad debts for such year. Held further, that the respondent did not abuse his discretion in disallowing as a deduction the full amount claimed as a reasonable addition to the reserve.
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Held, that since it has not been shown that a certain debt owing to Calavo, Inc. became worthless during the year in question, the amount of such debt may not be charged against the reserve for bad debts and thereby be reflected in the computation of the deductible addition to the reserve for bad debts for such year. Held further, that the respondent did not abuse his discretion in disallowing as a deduction the full amount claimed as a reasonable addition to the reserve. Section 166(c), Internal Revenue Code of 1954.
1Opinion of the Court
Calavo, Inc., and Calavo Growers of California, as successor to the assets and liabilities of Calavo, Inc. v. Commissioner.
Calavo, Inc. v. Commissioner
Docket No. 71187.
United States Tax Court
T.C. Memo 1960-242; 1960 Tax Ct. Memo LEXIS 47; 19 T.C.M. (CCH) 1359; T.C.M. (RIA) 60242;
November 17, 1960
Held, that since it has not been shown that a certain debt owing to Calavo, Inc. became worthless during the year in question, the amount of such debt may not be charged against the reserve for bad debts and thereby be reflected in the computation of the deductible addition to the reserve for bad…
2Cases cited7 opinions
- Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Black Motor Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Platt Trailer Co. v. CommissionerUnited States Tax Court · 1955
- New York Water Service Corp. v. CommissionerUnited States Tax Court · 1949
- Union National Bank & Trust Co. of Elgin v. CommissionerUnited States Tax Court · 1956
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