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ADELSON v. UNITED STATES

Appeal No. 85-2033.

782 F.2d 1010 (1986)

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

United States Court of Appeals, Federal Circuit.

January 29, 1986.

Attorney(s) appearing for the Case

Francis Allegra, Tax Div., Dept. of Justice, Washington, D.C., argued for appellant. With him on the brief were Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup and Carleton D. Powell.

Richard J. Innis, Hale and Dorr, Boston, Mass., argued for appellees. With him on the brief were Robert J. Richard, Peter M.C. Golemme and Barry C. Klickstein, Forman, Roberts, Klickstein and Levy, of Boston, Mass.

Before SMITH, Circuit Judge, SKELTON, Senior Circuit Judge, and BISSELL, Circuit Judge.

BISSELL, Circuit Judge.

The government appeals, for the second time, from a decision of the United States Claims Court (Spector, J.) deciding that Sheldon G. Adelson and Sandra Adelson (referred to jointly as Adelson or taxpayer) are 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)*.

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