Hunt Foods & Industries, Inc. v. Commissioner
United States Tax Court
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
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- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
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