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CERAND AND COMPANY, INC. v. COMMISSIONER

Docket No. 2767-97.

76 T.C.M. 933 (1998)

T.C. Memo. 1998-423

Cerand and Company, Inc. v. Commissioner.

United States Tax Court.

Filed November 24, 1998.

Attorney(s) appearing for the Case

Gerard A. Cerand (an officer), for the petitioner. Gregory S. Matson and Warren P. Simonsen, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined deficiencies in petitioner's Federal income tax for tax years 1990, 1991, and 1992 in the amounts of $6,994, $10,709, and $143,406, respectively. The issue for our consideration is whether bad debt deductions taken in 1990 and 1991 are allowable under section 166.1 The remainder of respondent's determination, the 1992 net operating loss (NOL) carryforward...

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