National-Standard Co. v. Commissioner
United States Tax Court
Petitioner borrowed Luxembourg francs from a Luxembourg bank to acquire a 50-percent interest in a Luxembourg corporation. When the first payment on the principal of the loan became due, petitioner borrowed Belgian francs (equal in dollar value to the Luxembourg francs) from a Belgian bank to refinance the loan.
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Petitioner borrowed Luxembourg francs from a Luxembourg bank to acquire a 50-percent interest in a Luxembourg corporation. When the first payment on the principal of the loan became due, petitioner borrowed Belgian francs (equal in dollar value to the Luxembourg francs) from a Belgian bank to refinance the loan. Later, after petitioner had sold the stock in the Luxembourg corporation, petitioner acquired Belgian francs from a Chicago bank to pay off the loan from the Belgian bank. Each time petitioner borrowed francs to pay off a bank loan, the value of the francs in U.S. dollars had…
1Opinion of the Court
OPINION
Drennen, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax for its taxable years ending September 30, 1974, and September 30, 1975, in the amounts of $179,971 and $149,350, respectively. Due to concessions by respondent, the only issue for decision is whether foreign currency exchange losses incurred by petitioner in each of the years in issue are deductible as ordinary losses, or instead, as capital losses.
The facts of this case were fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulated facts and exhibits attached…
2Cases cited21 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1939
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3Cited by35 opinions
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- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Zarin v. CommissionerUnited States Tax Court · 1989
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