Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $49,024.80 in petitioner's Federal income tax for 1986 and additions to tax of $2,451 and 50 percent of the interest due on $49,024.80 under section 6653(a)(1)(A) and (a)(1)(B), respectively. The issues for decision are (1) whether petitioner is entitled to a deduction for an addition to its reserve for bad debts in the amount that it claimed on its Federal income...
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