Legal Opinion

G.M. Trading Corp. v. Commissioner

United States Tax Court

Decided April 17, 1996No. Docket No. 6983-91Published

On reconsideration, we decline to alter any of the findings of fact or conclusions of law set forth in our prior opinion at 103 T.C. 59 (1994). Supplemental findings of fact and conclusions of law made. Held, we adhere to our prior holding that 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.

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On reconsideration, we decline to alter any of the findings of fact or conclusions of law set forth in our prior opinion at 103 T.C. 59 (1994). Supplemental findings of fact and conclusions of law made. Held, we adhere to our prior holding that 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. We also adhere to our prior findings and conclusions regarding the value of the pesos received and the amount of gain realized.

1Opinion of the Court

G.M. TRADING CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent *

G.M. Trading Corp. v. Commissioner

Docket No. 6983-91.

United States Tax Court

106 T.C. 257; 1996 U.S. Tax Ct. LEXIS 14; 106 T.C. No. 13;

April 17, 1996, Filed

Decision will be entered under Rule 155.

On reconsideration, we decline to alter any of the findings of fact or conclusions of law set forth in our prior opinion at 103 T.C. 59 (1994). Supplemental findings of fact and conclusions of law made.

Held, we adhere to our prior holding that petitioner is to be treated as having realized a taxable gain on the…

2Cases cited12 opinions

  1. Brown Shoe Co. v. CommissionerSupreme Court of the United States · 1950
  2. Lederer v. StocktonSupreme Court of the United States · 1922
  3. Esmark, Inc. v. CommissionerUnited States Tax Court · 1988
  4. Tandy Corp. v. CommissionerUnited States Tax Court · 1989
  5. Landau v. CommissionerUnited States Tax Court · 1946

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