MoneyGram International, Inc. and Subsidiaries v. Commissioner

153 T.C. No. 9

UNITED STATES TAX COURT MONEYGRAM INTERNATIONAL, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket Nos. 12231-12, 30309-12. Filed December 3, 2019. P, a U.S. corporation, is in the “money services business.” Its business involves the movement of money through three main chan- nels: money transfers, money orders, and payment processing serv- ices, including “official check” services for financial institutions. During 2007 and 2008 P undertook a recapitalization that included writing down or writing off a substantial volume of partially or…