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Paraphrase this The taxpayer in Allen, T.C. Memo. 2023-86, claimed bad debt deductions of over $17 million with respect to advances between companies the

Paraphrase this " The taxpayer in Allen, T.C. Memo. 2023-86, claimed bad debt deductions of over $17 million with respect to advances between companies the taxpayer controlled. The IRS denied the bad debt deductions, arguing that the advances represented equity, not debt. The Tax Court agreed and upheld the IRS's assessment of tax and penalties

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