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INTERGRAPH CORP. & SUBS. v. COMMISSIONER

Docket No. 21286-93.

106 T.C. 312 (1996)

INTERGRAPH CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 8, 1996.

Attorney(s) appearing for the Case

James R. McCann, David G. Glickman, Geoffrey R. Polma, and Sally C. Helppie, for petitioner.

Gary F. Walker, Kim Palmerino, and William T. Lundeen, for respondent.

SWIFT, Judge:

Respondent determined a deficiency of $978,567 with respect to Intergraph Corp. (Intergraph) and its subsidiaries' consolidated 1987 Federal income taxes.

After concessions, the issues for decision are: (1) The deductibility of a claimed $1,923,103 foreign currency loss and of a claimed $520,432 interest expense; and (2) if the first issue is decided against petitioner, the deductibility in the year of payment of a $6,484,169 bad debt...

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