Legal Opinion

Hunt Foods & Industries, Inc. v. Commissioner

United States Tax Court

Decided February 22, 1972No. Docket No. 4025-67Published

The petitioner sold its convertible debentures for a price which equaled or exceeded their stated redemption values. In this proceeding, it claimed a deduction for bond discount with respect to such debentures for 1962 and 1963. The claimed discount arose because the petitioner subtracted an amount equal to the value of the conversion privilege from the total price paid for each debenture.

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The petitioner sold its convertible debentures for a price which equaled or exceeded their stated redemption values. In this proceeding, it claimed a deduction for bond discount with respect to such debentures for 1962 and 1963. The claimed discount arose because the petitioner subtracted an amount equal to the value of the conversion privilege from the total price paid for each debenture. However, under secs. 1.163-3(a)(1) and 1.1232-3(b)(2)(i), Income Tax Regs., the issue price of a convertible debenture includes any amount paid in respect of the conversion privilege for purposes of…

1Opinion of the Court

Hunt Foods and Industries, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Hunt Foods & Industries, Inc. v. Commissioner

Docket No. 4025-67

United States Tax Court

57 T.C. 633; 1972 U.S. Tax Ct. LEXIS 180;

February 22, 1972, Filed

Decision will be entered under Rule 50.

The petitioner sold its convertible debentures for a price which equaled or exceeded their stated redemption values. In this proceeding, it claimed a deduction for bond discount with respect to such debentures for 1962 and 1963. The claimed discount arose because the petitioner subtracted an amount equal to the value…

2Cases cited20 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  3. Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
  4. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  5. Schulde v. CommissionerSupreme Court of the United States · 1963

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