Claymont Invs., Inc. v. Comm'r
United States Tax Court
F is a foreign corporation. P, a U.S. subsidiary of F, is a film processing company. On its amended 1992 and 1993 Federal income tax returns, P claimed sec. 165, I.R.C., loss deductions relating to the alleged termination of three customer relationships.
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F is a foreign corporation. P, a U.S. subsidiary of F, is a film processing company. On its amended 1992 and 1993 Federal income tax returns, P claimed sec. 165, I.R.C., loss deductions relating to the alleged termination of three customer relationships. In 1988, S1, a U.K. subsidiary of F, lent 29,498,525 (i.e., the equivalent of $ 50 million) to S2, a subsidiary of P. In 1996, S2 and S3 (i.e., another subsidiary of P), entered into a note assumption agreement, which provided that S3 would assume S2's obligations relating to the 1988 loan. Because of the favorable currency exchange rates…
1Opinion of the Court
CLAYMONT INVESTMENTS, INC., AS SUCCESSOR IN INTEREST TO NEW CCI, INC. AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Claymont Invs., Inc. v. Comm'r
Nos. 14384-99, 9129-00
United States Tax Court
T.C. Memo 2005-254; 2005 Tax Ct. Memo LEXIS 252; 90 T.C.M. (CCH) 462;
October 31, 2005, Filed
F is a foreign corporation. P, a U.S. subsidiary of F, is a film processing company. On its amended 1992 and 1993 Federal income tax returns, P claimed sec. 165, I.R.C., loss deductions relating to the alleged termination of three customer relationships. In 1988, S1, a U.K. subsidiary…
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