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AMERICAN OFFSHORE, INC. v. COMMISSIONER

Docket No. 15225-86.

97 T.C. 579 (1991)

AMERICAN OFFSHORE, INC., AMERICAN VESSELS, INC., AND SUBSIDIARIES, AND ZODIAC OFFSHORE, INC., AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 25, 1991.

Attorney(s) appearing for the Case

Lawrence Kalinec, Jasper G. Taylor III, Ronald W. Adzgery, and Hugh E. Tanner, for the petitioners.

Melanie R. Urban and John F. Eiman, for the respondent.

COLVIN, Judge:

In this case we decide whether petitioners are entitled to bad debt deductions under section 1661 in 1983 for an $11 million subordinated promissory note, and for transfers of funds to Offshore Machinery, Inc.

Respondent determined deficiencies in petitioners' income taxes as follows:

 Petitioner                 Taxable period ending       Deficiency

American Offshore, Inc...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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