Legal Opinion
Edison Homes, Inc., Formerly Ardmor, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided July 9, 1990No. 89-1708PublishedCited by 4 opinions
1Opinion of the Court
BEAM, Circuit Judge.
Edison Homes, Inc., taxpayer, appeals from a judgment entered by the United States Tax Court upholding a deficiency in its 1981 income tax payments. The Commissioner disallowed taxpayer’s deduction of $528,024 for an addition to its bad debt reserve under 26 U.S.C. § 166(f) (1982), 1 and assessed a tax deficiency of $251,665. The Commissioner also assessed Edison Homes with an addition to tax for negligence, pursuant to 26 U.S.C. § 6653(a) (1982). The tax court upheld the Commissioner’s determination that taxpayer had not met its burden of proving that the Commissioner’s…
2Cases cited10 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Arnold T. Forseth, Gerald R. Formsma and Constance Y. Formsma v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Stephen B. Scallen and Chacke Y. Scallen v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1989
- Roth Steel Tube Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- Beneficial Corporation and Subsidiaries v. The United StatesCourt of Appeals for the Federal Circuit · 1987
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3Cited by4 opinions
- Gerald Leuhsler, Beverly Leuhsler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
- Joseph P. Caulfield v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994
- Bank of Kirksville v. United StatesDistrict Court, W.D. Missouri · 1996
- Sears Imported Autos, Inc. v. CommissionerUnited States Tax Court · 1992