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ATLANTIC DISCOUNT COMPANY, INC. v. UNITED STATES

No. 72-2289.

473 F.2d 412 (1973)

ATLANTIC DISCOUNT COMPANY, INC., Plaintiff-Appellee-Cross Appellant, v. UNITED STATES of America, Defendant-Appellant-Cross Appellee.

United States Court of Appeals, Fifth Circuit.

January 30, 1973.

Attorney(s) appearing for the Case

John L. Briggs, U. S. Atty., Jacksonville, Fla., Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Meyer Rothwacks, Donald H. Olson, Attys., Tax Division, U. S. Dept. of Justice, Washington, D. C., for appellant.

William R. Frazier, Fred M. Ringel, Jacksonville, Fla., for appellee.

Before GOLDBERG, AINSWORTH and INGRAHAM, Circuit Judges.

AINSWORTH, Circuit Judge:

Atlantic Discount, Inc. is engaged in the business of financing both retail and wholesale purchasers of automobiles and other consumer goods. In anticipation of a certain percentage of loans being uncollectible, Atlantic established a reserve for bad debts. At issue in this case is the reasonableness of Atlantic's additions to the reserve for the years 1963 and 1964, which were deducted for tax purposes...

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