Legal Opinion
CMI International, Inc., a Michigan Corporation v. Commissioner
United States Tax Court
Decided July 13, 1999No. 24752-92Unknown
1Opinion of the Court
113 T.C. No. 1
UNITED STATES TAX COURT CMI INTERNATIONAL, INC. A MICHIGAN CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24752-92. Filed July 13, 1999. P's wholly owned domestic subsidiary, D, participated in a debt-equity-swap transaction in which D exchanged an interest in Mexican U.S.-dollar- denominated debt for stock in D's Mexican subsidiary. On its consolidated 1988 tax return, P reported no gain or loss relating to the swap transaction. In the notice of deficiency, respondent determined that P recognized an $830,000 gain relating to the transaction.…
2Cases cited9 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Danielson v. CommissionerUnited States Tax Court · 1965
- North American Rayon Corporation, Formerly Known as North American Holding Corporation, Narco v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1994
- Estate of Durkin v. CommissionerUnited States Tax Court · 1992
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