Legal Opinion
G.M. Trading Corp. v. Commissioner
Court of Appeals for the Fifth Circuit
Decided September 23, 1997No. 96-60679PublishedCited by 24 opinions
1Opinion of the Court
JERRY E. SMITH, Circuit Judge:
G.M. Trading Corporation (“G.M.”) surrendered $600,000 worth of Mexican national debt to the Mexican government and received approximately 1.7 billion pesos restricted to the construction of a plant in Mexico. The Tax Court found that G.M. recognized $410,000 of gain. Concluding, to the contrary, that the pesos received in exchange for the debt extinguishment were worth $600,000, and the balance of the value received constituted a nontaxable contribution to capital, we reverse and render judgment for the taxpayer.
I
A
In the late 1980’s, the Mexican government…
2Cases cited35 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Pioneer Investment Services Co. v. Brunswick Associates Ltd. PartnershipSupreme Court of the United States · 1993
- Freytag v. CommissionerSupreme Court of the United States · 1991
- United States v. CartwrightSupreme Court of the United States · 1973
- United States v. DavisSupreme Court of the United States · 1962
30 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Andrews & Kurth L.L.P. v. Family Snacks, Inc. (In Re Pro-Snax Distributors, Inc.)Court of Appeals for the Fifth Circuit · 1998
- Buffalo Marine Services Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 2011
- Stanford v. CommissionerCourt of Appeals for the Fifth Circuit · 1998
- Georg Schaeffler v. United StatesCourt of Appeals for the Fifth Circuit · 2018
- Copeland v. CommissionerCourt of Appeals for the Fifth Circuit · 2002
19 more not listed; retrieve them via the Exa API.