Legal Opinion
Chock Full O' Nuts Corporation v. United States
Court of Appeals for the Second Circuit
Decided December 21, 1971No. 156, Docket 71-1536PublishedCited by 63 opinions
1Opinion of the Court
MANSFIELD, Circuit Judge:
This appeal raises the question, apparently one of first impression, whether a corporation which has issued callable convertible bonds at par is entitled under the Internal Revenue Code of 1954 and the Treasury Regulations promulgated thereunder by the Commissioner of Internal Revenue to deduct as “original issue discount” that part of the issue price allocable to the conversion feature.
The factual background is undisputed. Appellant Chock Full O’ Nuts Corporation (“the taxpayer”), a New York corporation engaged in the importing and sale of coffee and other food…
2Cases cited18 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Welch v. HenrySupreme Court of the United States · 1938
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Helvering v. ReynoldsSupreme Court of the United States · 1941
13 more not listed; retrieve them via the Exa API.
3Cited by63 opinions
- Anderson, Clayton & Co., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Esden v. Bank of BostonCourt of Appeals for the Second Circuit · 2000
- CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
- Miller v. CommissionerUnited States Tax Court · 1985
58 more not listed; retrieve them via the Exa API.