Bad-debt deductions for written-off commodity receivables were allowed, while windmill-profit expense allocation required fresh factual examination.
X X X X Extracts X X X X
X X X X Extracts X X X X
....Commodity-trading receivables written off as bad debts qualify for deduction where they were previously included in income and written off in the books; a possible future recovery does not justify disallowance. Characterising the transactions as speculative or the amount as capital investment does not displace fulfilment of those conditions. The bad-debt disallowance was deleted, subject to taxation of any later recovery in the year received. For windmill-profit deductions, head-office expenses and depreciation on common assets require factual examination of their components, use and allocation to eligible operations. That computation was remanded for fresh adjudication.....
TaxTMI