G.M. Trading Corp. v. Commissioner
United States Tax Court
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
- Cottage Savings Assn. v. CommissionerSupreme Court of the United States · 1991
- United States v. Chicago, Burlington & Quincy RailroadSupreme Court of the United States · 1973
- Eder v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943
- National-Standard Co. v. CommissionerUnited States Tax Court · 1983
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
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3Cited by11 opinions
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- CMI Int'l, Inc. v. CommissionerUnited States Tax Court · 1999
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