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EDISON HOMES, INC. v. C.I.R.

No. 89-1708.

903 F.2d 579 (1990)

EDISON HOMES, INC., formerly Ardmor, Inc., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided May 17, 1990.

Rehearing and Rehearing Denied July 9, 1990.

Attorney(s) appearing for the Case

Jack S. Nordby, Minneapolis, Minn., for appellant.

Patricia M. Bowman, Washington, D.C., for appellee.

Before LAY, Chief Judge, BEAM, Circuit Judge and WOODS, District Judge.

Rehearing and Rehearing En Banc Denied July 9, 1990.

BEAM, Circuit Judge.

Edison Homes, Inc., taxpayer, appeals from a judgment entered by the United States Tax Court upholding a deficiency in its 1981 income tax payments. The Commissioner disallowed taxpayer's deduction of $528,024 for an addition to its bad debt reserve under 26 U.S.C. § 166(f) (1982),1 and assessed a tax deficiency of $251,665. The Commissioner also assessed...

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