Pechiney Ugine Kuhlmann Corp. v. Commissioner
United States Tax Court
Petitioner (P) is a Delaware corporation which owned certain interest bearing convertible debentures of H, another Delaware corporation. P sold the debentures on June 18, 1970, at fair market value to I, a Netherlands Antilles corporation which was an indirectly wholly owned foreign subsidiary of one of P's two foreign corporate shareholders. P sustained a $5,078,691 capital loss which generated a $720,163 net operating loss carryback to P's 1969 tax year.
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Petitioner (P) is a Delaware corporation which owned certain interest bearing convertible debentures of H, another Delaware corporation. P sold the debentures on June 18, 1970, at fair market value to I, a Netherlands Antilles corporation which was an indirectly wholly owned foreign subsidiary of one of P's two foreign corporate shareholders. P sustained a $5,078,691 capital loss which generated a $720,163 net operating loss carryback to P's 1969 tax year. Held, the capital loss sustained by P is allowable as a deduction under section 165, I.R.C. 1954.
1Opinion of the Court
PECHINEY UGINE KUHLMANN CORP. AND SUBSIDIARY FORMERLY: PECHINEY ENTERPRISES, INCORPORATED AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Pechiney Ugine Kuhlmann Corp. v. Commissioner
Docket No. 276-81.
United States Tax Court
T.C. Memo 1986-244; 1986 Tax Ct. Memo LEXIS 363; 51 T.C.M. (CCH) 1210; T.C.M. (RIA) 86244;
June 17, 1986.
Petitioner (P) is a Delaware corporation which owned certain interest bearing convertible debentures of H, another Delaware corporation. P sold the debentures on June 18, 1970, at fair market value to I, a Netherlands Antilles corporation…
2Cases cited10 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Falsetti v. CommissionerUnited States Tax Court · 1985
- Crown Cork International Corp. v. CommissionerUnited States Tax Court · 1944
- Widener, Trust No. 5 v. CommissionerUnited States Tax Court · 1983
- Transport Manufacturing & Equipment Company of Delaware v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1970
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