Bad-debt deduction was available where full invoice amounts had been recognised as income, retained sums remained receivables, and those receivables were written off as irrecoverable; the related disallowance was deleted without requiring proof that the debts became bad in a particular year. Related-party rent could not be disallowed without comparable or other material establishing excessiveness or unreasonableness against fair market value; suspicion or an allegation of non-revenue neutrality was insufficient, and the disallowance was deleted. A challenge confined to initiation of penalty proceedings was premature and was dismissed.
Bad-debt deduction was available where full invoice amounts had been recognised as income, retained sums remained receivables, and those receivables were written off as irrecoverable; the related disallowance was deleted without requiring proof that the debts became bad in a particular year. Related-party rent could not be disallowed without comparable or other material establishing excessiveness or unreasonableness against fair market value; suspicion or an allegation of non-revenue neutrality was insufficient, and the disallowance was deleted. A challenge confined to initiation of penalty proceedings was premature and was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
