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ROTH STEEL TUBE CO. v. C. I. R.

No. 77-1588.

620 F.2d 1176 (1980)

ROTH STEEL TUBE COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided May 8, 1980.

Attorney(s) appearing for the Case

Bennet Kleinman, Laurence Glazer, Kahn, Kleinman, Yanowitz & Arnson, Cleveland, Ohio, for petitioner-appellant.

M. Carr Ferguson, Joseph L. Liegl, Michael L. Paup, Asst. Attys. Gen., Tax Div., U.S. Dept. of Justice, Washington, D. C., Gilbert E. Andrews, Stuart E. Seigel, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Before CELEBREZZE, LIVELY and ENGEL, Circuit Judges.

ENGEL, Circuit Judge.

Petitioner Roth Steel Tube Company (Roth) appeals from the Tax Court's ruling disallowing a deduction of $172,443 as an addition to Roth's reserve for bad debts for the tax year ended April 30, 1972.1 We affirm.

I.

In its tax year ended April 30, 1972, Roth charged $172,443 against its reserve for bad debts in connection with the partial write-off of an account receivable. At the time that Roth attempted...

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