Legal Opinion

Golden Nugget, Inc. v. Commissioner

United States Tax Court

Decided July 18, 1984No. Docket Nos. 8027-81, 11098-83Published

Golden Nugget, Inc., in 1974, exchanged debentures due in 1994 for about 11 percent of its outstanding common stock and here claims an annual deduction for original issue discount with respect to the difference between the principal amount of the debentures and the fair market value of the common stock at the time of the exchange.

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Golden Nugget, Inc., in 1974, exchanged debentures due in 1994 for about 11 percent of its outstanding common stock and here claims an annual deduction for original issue discount with respect to the difference between the principal amount of the debentures and the fair market value of the common stock at the time of the exchange. Held, petitioner's exchange of the debentures for the common stock was a reorganization in the form of a recapitalization under sec. 368(a)(1)(E), I.R.C. 1954, and hence under sec. 1232(b)(1), I.R.C. 1954, the issue price of the debentures was their stated…

1Opinion of the Court

Golden Nugget, Inc., and Subsidiary, Petitioner v. Commissioner of Internal Revenue, Respondent

Golden Nugget, Inc. v. Commissioner

Docket Nos. 8027-81, 11098-83

United States Tax Court

83 T.C. 28; 1984 U.S. Tax Ct. LEXIS 49; 83 T.C. No. 4;

July 18, 1984. July 18, 1984, Filed

Decisions will be entered for the respondent.

Golden Nugget, Inc., in 1974, exchanged debentures due in 1994 for about 11 percent of its outstanding common stock and here claims an annual deduction for original issue discount with respect to the difference between the principal amount of the debentures and the fair market value…

2Cases cited40 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  3. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  4. Dixon v. United StatesSupreme Court of the United States · 1965
  5. Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974

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