Reynolds Metals Co. v. Commissioner
United States Tax Court
In 1969, S, P's wholly owned subsidiary, issued debentures, convertible into shares of common stock of P. In 1987, S called the debentures for redemption, thereby prompting most debenture holders to convert their debentures into P's common stock. The converted debentures were subsequently redeemed by S for cash in an amount equal to the principal of the debentures with accrued interest.
Read the full summary
In 1969, S, P's wholly owned subsidiary, issued debentures, convertible into shares of common stock of P. In 1987, S called the debentures for redemption, thereby prompting most debenture holders to convert their debentures into P's common stock. The converted debentures were subsequently redeemed by S for cash in an amount equal to the principal of the debentures with accrued interest. P and its consolidated subsidiaries claimed a capital loss deduction under sec. 165(f), I.R.C., in the amount by which the fair market value of P's stock issued in the exchange exceeded the principal of the…
1Opinion of the Court
REYNOLDS METALS COMPANY AND CONSOLIDATED SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Reynolds Metals Co. v. Commissioner
Docket No. 24939-93.
United States Tax Court
105 T.C. 304; 1995 U.S. Tax Ct. LEXIS 56; 105 T.C. No. 20;
October 16, 1995, Filed
Decision will be entered under Rule 155.
In 1969, S, P's wholly owned subsidiary, issued debentures, convertible into shares of common stock of P. In 1987, S called the debentures for redemption, thereby prompting most debenture holders to convert their debentures into P's common stock. The converted debentures were…
2Cases cited21 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- United States v. Chicago, Burlington & Quincy RailroadSupreme Court of the United States · 1973
- Chock Full O' Nuts Corporation v. United StatesCourt of Appeals for the Second Circuit · 1971
- Commissioner v. FinkSupreme Court of the United States · 1987
16 more not listed; retrieve them via the Exa API.