Roanoke Vending Exchange, Inc. v. Commissioner
United States Tax Court
Petitioner was in the business of selling automatic coin vending and amusement type machines to operators. It had elected the reserve method of handling bad debts and in 1956 and 1957, pursuant to sec. 166(c) of the 1954 Code, deducted certain amounts from its adjusted gross income as additions to the reserve for bad debts.
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Petitioner was in the business of selling automatic coin vending and amusement type machines to operators. It had elected the reserve method of handling bad debts and in 1956 and 1957, pursuant to sec. 166(c) of the 1954 Code, deducted certain amounts from its adjusted gross income as additions to the reserve for bad debts. Held, petitioner failed to establish that the additions to the reserve for bad debts for 1956 and 1957 were reasonable within the meaning of sec. 166(c) of the 1954 Code.
1Opinion of the Court
Fisher, Judge:
Respondent determined deficiencies in the income tax of petitioner for the taxable years 1956 and 1957 of $4,970.41 and $7,344.26, respectively.
The issue involved herein is whether annual additions to petitioner’s bad debt reserve for 1956 and 1957 were unreasonable and excessive.
FINDINGS OF FACT
Some of the facts were stipulated. Those so stipulated are found accordingly and incorporated herein by this reference.
Roanoke Vending Exchange, Inc. (sometimes 'hereinafter referred to as petitioner), was incorporated in 1948 under the laws of the State of Virginia. Its offices and…
2Cases cited16 opinions
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