Philip Morris Inc. v. Commissioner
United States Tax Court
P borrowed in foreign currencies which it converted into U.S. dollars and later repaid the borrowings in the same foreign currency which it had purchased with U.S. dollars.
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P borrowed in foreign currencies which it converted into U.S. dollars and later repaid the borrowings in the same foreign currency which it had purchased with U.S. dollars. P reported its gain, represented by the difference in U.S. dollars between the value of the foreign currencies at the time of the borrowings and the U.S. dollar cost of the currencies used for repayment, as income from the discharge of indebtedness and elected to exclude such income from gross income under sec. 108, I.R.C., and reduce the basis in its assets under sec. 1017, I.R.C.Held: P's gain does not constitute income…
1Opinion of the Court
Philip Morris Incorporated, Petitioner v. Commissioner of Internal Revenue, Respondent
Philip Morris Inc. v. Commissioner
Docket No. 28279-92
United States Tax Court
104 T.C. 61; 1995 U.S. Tax Ct. LEXIS 4; 104 T.C. No. 3;
January 23, 1995, Filed
Decision will be entered under Rule 155.
P borrowed in foreign currencies which it converted into U.S. dollars and later repaid the borrowings in the same foreign currency which it had purchased with U.S. dollars. P reported its gain, represented by the difference in U.S. dollars between the value of the foreign currencies at the time of the borrowings and…
2Cases cited24 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
- United States v. Centennial Savings Bank FSBSupreme Court of the United States · 1991
- Bernard A. Levin, Phyllis Levin, Alan T. Hrabosky, and Delores Hrabosky v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
- Levin v. CommissionerUnited States Tax Court · 1986
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