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ABC BEVERAGE CORP. v. COMMISSIONER

Docket No. 14868-02.

92 T.C.M. 268 (2006)

T.C. Memo. 2006-195

ABC Beverage Corp., F.K.A. Beverage America, Inc. v. Commissioner.

United States Tax Court.

September 11, 2006.

Attorney(s) appearing for the Case

Ronald G. Dewaard and Kaplin S. Jones, for petitioner.

Lawrence C. Letkewicz and David Flassing, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge.

Respondent determined a $5,169,946 deficiency in petitioner's Federal income tax for 1995 by denying petitioner a $10 million partial bad debt deduction under section 166.1 After concessions,2 we must determine whether $10 million of an $18 million debt became worthless in 1995.

FINDINGS OF FACT

Some of the facts have been stipulated...

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