Sheldon G. Adelson and Sandra Adelson v. The United States

BISSELL, Circuit Judge.

The government appeals, for the second time, from a decision of the United States Claims Court (Spector, J.) deciding that Sheldon G. Adelson and Sandra Adelson (referred to jointly as Adelson or taxpayer) are entitled to a refund of $163,506.16, plus interest, based on what the court determined was a reasonable addition to a bad debt reserve under I.R.C. § 166(c) (1982) * .

In this court’s decision to the government’s first appeal (Adelson I), we affirmed the holding of the Claims Court that taxpayer’s advances to the client-companies were bona fide debts, 737 F.2d at…