Winter & Hirsch, Inc. v. United States

*519This tax refund suit is before the court on defendant’s motion for partial summary judgment. Plaintiff claims it is entitled to an additional deduction in fiscal year 1963 of $661,386.28 as a reasonable addition to its bad debts reserve on account of debts which admittedly became worthless in prior taxable years. Defendant maintains plaintiff is not so entitled. After careful consideration of the briefs and oral arguments, we grant defendant’s motion for partial summary judgment.

The plaintiff is a corporation which ceased doing active business in 1970. Prior to that time, plaintiff was in the…