Legal Opinion

G.M. Trading Corp. v. Commissioner

United States Tax Court

Decided July 25, 1994No. Docket No. 6983-91PublishedCited by 11 opinions

Petitioner participated in a "Mexican debt-equity-swap" transaction. Held: Petitioner is to be treated as having realized a taxable gain on the exchange of U.S. dollar-denominated Mexican Government debt for Mexican pesos. The value of the pesos received and the amount of gain determined.

1Opinion of the Court

Swift, Judge:

Respondent determined a deficiency in petitioner’s 1988 Federal income tax and additions to tax as follows:

Additions to tax

Deficiency Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B)

$289,141 $14,457 50% of the interest due on the portion of the underpayment attributable to negligence

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

After settlement, the primary issue for decision involves the proper Federal income tax treatment of a so-called…

2Cases cited16 opinions

  1. Cottage Savings Assn. v. CommissionerSupreme Court of the United States · 1991
  2. United States v. Chicago, Burlington & Quincy RailroadSupreme Court of the United States · 1973
  3. Eder v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943
  4. National-Standard Co. v. CommissionerUnited States Tax Court · 1983
  5. Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993

11 more not listed; retrieve them via the Exa API.

3Cited by11 opinions

  1. G.M. Trading Corp. v. CommissionerCourt of Appeals for the Fifth Circuit · 1997
  2. G.M. Trading Corp. v. CommissionerUnited States Tax Court · 1996
  3. Norwest Corp. v. Comm'rUnited States Tax Court · 1997
  4. CMI Int'l, Inc. v. CommissionerUnited States Tax Court · 1999
  5. CMI Int'l, Inc. v. CommissionerUnited States Tax Court · 1999

6 more not listed; retrieve them via the Exa API.

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