Husky Oil Co. v. Commissioner
United States Tax Court
In 1972, P issued debentures which were convertible into shares of common stock of its foreign parent. In 1977, P called the debentures for redemption, thereby prompting most debenture holders to convert their debentures into the parent's common stock. The converted debentures were then redeemed from the parent by the issuance of interest-bearing promissory notes.
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In 1972, P issued debentures which were convertible into shares of common stock of its foreign parent. In 1977, P called the debentures for redemption, thereby prompting most debenture holders to convert their debentures into the parent's common stock. The converted debentures were then redeemed from the parent by the issuance of interest-bearing promissory notes. Held, the interest and premium paid by P to its parent upon the converted debentures are not deductible by P. Held, further, the unamortized issue costs of the debentures and costs of redemption must be amortized over the lives of…
1Opinion of the Court
Husky Oil Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Husky Oil Co. v. Commissioner
Docket No. 21433-81
United States Tax Court
83 T.C. 717; 1984 U.S. Tax Ct. LEXIS 14; 83 T.C. No. 41;
November 23, 1984; As Amended December 18, 1984 November 23, 1984, Filed
Decision will be entered under Rule 155.
In 1972, P issued debentures which were convertible into shares of common stock of its foreign parent. In 1977, P called the debentures for redemption, thereby prompting most debenture holders to convert their debentures into the parent's common stock. The converted debentures were…
2Cases cited23 opinions
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- Burnet v. HarmelSupreme Court of the United States · 1932
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Lynch v. Alworth-Stephens Co.Supreme Court of the United States · 1925
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