The Fed-Mart Corporation, a California Corporation v. The United States of America

HARPER, Senior District Judge.

Appellant, Fed-Mart Corporation, appeals from the judgment of the District Court in favor of the United States in consolidated actions for the refund of Federal income taxes for the taxpayer’s fiscal years 1967 through 1970. The appellant contends that it is entitled to a debt discount deduction arising from the exchange of junior subordinated 6V2% debentures for shares of its outstanding stock.

Fed-Mart is a California corporation engaged in the business of discount retailing. On March 3, 1967, Fed-Mart made an exchange offer to the holders of its common stock…