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FOSTER FROSTY FOODS, INC. v. C. I. R.

No. 7425.

332 F.2d 230 (1964)

FOSTER FROSTY FOODS, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Tenth Circuit.

May 21, 1964.

Attorney(s) appearing for the Case

James P. Turner, Pueblo, Colo. (James E. Carpenter and Calkins, Rodden & Kramer, Denver, Colo., of counsel, with him on the brief), for petitioner.

Benjamin M. Parker, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., and Lee A. Jackson and Harry Baum, Washington, D. C., with him on the brief), for respondent.

Before MURRAH, Chief Judge, and PICKETT and LEWIS, Circuit Judges.

LEWIS, Circuit Judge.

This is a petition for review of a decision of the Tax Court holding that the determinative issue of the case was whether discounted notes could be considered as a factor in establishing a deduction for a reasonable addition to a reserve for bad debts under 26 U.S.C. § 166(c) and deciding that issue in accordance with the Commissioner's determination that such discounted notes could not be so considered...

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