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BUDGET CREDITS, INC. v. C. I. R.

No. 19028.

417 F.2d 1108 (1969)

BUDGET CREDITS, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals Sixth Circuit.

October 16, 1969.

Attorney(s) appearing for the Case

Miles Jaffe, Detroit, Mich. (Jason L. Honigman, Honigman, Miller, Schwartz & Cohn, Detroit, Mich., on the brief), for appellant.

Ann E. Belanger, Dept. of Justice, Washington, D. C. (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, William A. Friedlander, Attys., Dept. of Justice, Washington, D. C., on the brief), for appellee.

Before PECK, McCREE and COMBS, Circuit Judges.

PER CURIAM.

The Commissioner of Internal Revenue assessed income tax deficiencies totalling $100,024.98 against appellant taxpayer for the fiscal years ending July, 1960 through 1963. These deficiencies resulted from the Commissioner's disallowance of certain additions to taxpayer's reserve for bad debts during the years in question. The Tax Court, two judges dissenting, upheld the Commissioner's assessments, and it is from that decision taxpayer appeals.

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