G.M. Trading Corp. v. Commissioner
United States Tax Court
On reconsideration, we decline to alter any of the findings of fact or conclusions of law set forth in our prior opinion at 103 T.C. 59 (1994). Supplemental findings of fact and conclusions of law made. Held, we adhere to our prior holding that petitioner is to be treated as having realized a taxable gain on the exchange of U.S. dollar-denominated Mexican Government debt for Mexican pesos.
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On reconsideration, we decline to alter any of the findings of fact or conclusions of law set forth in our prior opinion at 103 T.C. 59 (1994). Supplemental findings of fact and conclusions of law made. Held, we adhere to our prior holding that petitioner is to be treated as having realized a taxable gain on the exchange of U.S. dollar-denominated Mexican Government debt for Mexican pesos. We also adhere to our prior findings and conclusions regarding the value of the pesos received and the amount of gain realized.
1Opinion of the Court
SUPPLEMENTAL OPINION
Swift, Judge:
This matter is before us on reconsideration of our opinion at 103 T.C. 59 (1994), in which we concluded that petitioner realized a taxable gain in connection with a “Mexican debt-equity-swap” transaction. On October 13, 1994, we granted petitioner’s motion for reconsideration, and we requested that petitioner and respondent file briefs on the points raised in petitioner’s motion for reconsideration. We also allowed amici briefs to be filed by Chrysler Corp. and by Harold L. Adrion. .
On reconsideration, petitioners and the amici curiae make three primary…
2Cases cited11 opinions
- Brown Shoe Co. v. CommissionerSupreme Court of the United States · 1950
- Lederer v. StocktonSupreme Court of the United States · 1922
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- Tandy Corp. v. CommissionerUnited States Tax Court · 1989
- Landau v. CommissionerUnited States Tax Court · 1946
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