ON DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT
KASHIWA, Judge.
This tax refund suit is before the court on defendant's motion for partial summary judgment. Plaintiff claims it is entitled to an additional deduction in fiscal year 1963 of $661,386.28 as a reasonable addition to its bad debts reserve on account of debts which admittedly became worthless in prior taxable years. Defendant maintains plaintiff is not so entitled. After careful consideration...
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