International Multifoods Corporation and Affiliated Companies v. Commissioner

108 T.C. No. 26

UNITED STATES TAX COURT INTERNATIONAL MULTIFOODS CORPORATION AND AFFILIATED COMPANIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11643-92. Filed June 18, 1997. On Mar. 30, 1987, P, a domestic corporation, entered into an agreement with Borden to sell P's stock in Paty, a limitada organized under the laws of the Federal Republic of Brazil. P realized a loss upon the sale of the Paty stock, which P reported as a U.S. source loss for purposes of its foreign tax credit computation under sec. 904(a), I.R.C. R determined that the loss was foreign source.…