National Alfalfa Dehydrating & Milling Co. v. Commissioner
United States Tax Court
Petitioner, a corporation with its principal office at the time the petition in this case was filed in Shawnee Mission, Kans., in July 1957, pursuant to a resolution providing for a reorganization and recapitalization, issued its debenture bonds of a face amount of $ 50 in exchange for its preferred stock of a par value of $ 50 and canceled the preferred stock received in the exchange.
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Petitioner, a corporation with its principal office at the time the petition in this case was filed in Shawnee Mission, Kans., in July 1957, pursuant to a resolution providing for a reorganization and recapitalization, issued its debenture bonds of a face amount of $ 50 in exchange for its preferred stock of a par value of $ 50 and canceled the preferred stock received in the exchange. At the date of the exchange the preferred stock was quoted on the "over-the-counter" market at prices averaging around $ 33 per share. Petitioner, for its fiscal years ended Apr. 30, 1958, through Apr. 30,…
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined a deficiency in petitioner’s income tax for the fiscal year ended April 30, 1967, in the amount of $147,949.76.
The issue for decision is whether petitioner is entitled to a deduction for amortizable debt discount measured by the difference between the face value of its corporate bonds and the fair market value of its preferred stock which it received in exchange for the bonds.
All of the facts have been stipulated and are found accordingly.
National Alfalfa Dehydrating & Milling Co. (hereinafter referred to as petitioner or National Alfalfa) is a…
2Cases cited13 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Helvering v. Union Pacific RailroadSupreme Court of the United States · 1934
- Nassau Lens Co., Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Harry Pildes and Sarah PildesCourt of Appeals for the Second Circuit · 1962
- Southern Natural Gas Company v. The United StatesUnited States Court of Claims · 1969
- The Montana Power Company v. United StatesCourt of Appeals for the Third Circuit · 1956
8 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Gulf, Mobile and Ohio Railroad Company, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1978
- GULF, MOBILE AND OHIO RAILROAD CO. v. United StatesDistrict Court, S.D. Alabama · 1972
- National Alfalfa Dehydrating and Milling Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
- Magneson v. CommissionerUnited States Tax Court · 1983
4 more not listed; retrieve them via the Exa API.