DAWSON, Chief Judge:
Respondent determined a deficiency of $85,755 in petitioner's Federal income taxes for the taxable year ended April 30, 1972. Such deficiency resulted from the disallowance of petitioner's claimed addition to its bad debt reserve in the amount of $178,656. The two issues presented for decision are:
(1) Whether petitioner properly charged its reserve for bad debts in the amount of $172,443 in connection with the partial writeoff...
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