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Current Federal Tax Developments · Dec 18, 2025

Substantiating Bad Debt Deductions and NOL Carryovers: An Analysis of Fussell v. Commissioner

Tax Brief summary and classification of the original reporting.

Bottom Line

💡 Substantiating Bad Debt Deductions and NOL Carryovers: An Analysis of Fussell.... Worth reviewing for potential client impact.

Summary

In the recent Tax Court Memorandum decision Fussell v. Commissioner, T.C. Memo. 2025-131, the Tax Court offered a stark reminder regarding the stringent substantiation requirements for business bad debts under Internal Revenue Code (IRC) Section 166 and the mechanical application of Net Operating...

Classification

Category: fyiPriority: importantReason: Contains 'tax court' - significant update

Affected Groups

All tax practitioners

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Original Source

We aggregate public tax updates and provide AI-assisted summaries. Please read the original reporting for full details.

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