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THOMPSON v. C.I.R.

Nos. 83-1393 to 83-1397.

761 F.2d 259 (1985)

DeWitt C. THOMPSON, III, and Diana R. Thompson (83-1393, 83-1396), Thompson & Green Machinery Company, Inc. (83-1394, 83-1395, 83-1397), Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided April 29, 1985.

Attorney(s) appearing for the Case

Mark H. Westlake (argued), Tune, Entrekin and White, Nashville, Tenn., for petitioners-appellants.

Kenneth W. Gideon, Chief Counsel, I.R.S., Glenn L. Archer, Jr., (Lead Counsel), Michael L. Paup, Tax Div., Dept. of Justice, Jonathan S. Cohen, Joan I. Oppenheimer (argued), Washington, D.C., for respondent-appellee.

Before MERRITT, MARTIN and JONES, Circuit Judges.

BOYCE F. MARTIN, Jr., Circuit Judge.

This is an appeal from a decision of the Tax Court, T.C.M. (P-H) ¶ 83,081 (1983), holding that certain bad debt expenses taken by a Tennessee heavy equipment dealer were improperly taken under the reserve for bad debts section, 166(c), of the Internal Revenue Code. We affirm in part and reverse in part.

The taxpayers in this case are Thompson & Green Machinery Company, Inc., a Nashville, Tennessee, dealer in heavy...

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