ADELSON v. UNITED STATES

Appeal No. 83-1300.

737 F.2d 1569 (1984)

Sheldon G. ADELSON and Sandra Adelson, Appellees, v. The UNITED STATES, Appellant.

United States Court of Appeals, Federal Circuit.

June 28, 1984.


Attorney(s) appearing for the Case

Carleton D. Powell, Washington, D.C., argued for appellant. With him on the brief were Glenn L. Archer, Jr., Asst. Atty. Gen., Theodore D. Peyser, Jr. and Ellen C. Specker, Washington, D.C.

Timothy H. Gailey, Boston, Mass., argued for appellees. With him on the brief was Barry C. Klickstein, Boston, Mass., of counsel.

Before BENNETT, Circuit Judge, COWEN, Senior Circuit Judge, and MILLER, Circuit Judge.


BENNETT, Circuit Judge.

The government appeals from a judgment of the United States Claims Court (Spector, J.) holding that Sheldon G. Adelson (taxpayer)1 is entitled to a refund of $163,506.16, plus interest, based on what the court determined was a reasonable addition to a bad debt reserve under I.R.C. § 166(c) (1982). In its initial opinion, the court held that taxpayer's advances to seven client-companies were bona fide debts...

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