Legal Opinion

Corporacion de Ventas de Salitre y Yoda v. Commissioner

United States Board of Tax Appeals

Decided May 6, 1941No. Docket No. 97315Published

1. Petitioner, a foreign corporation, realized gain from the purchase of its own American debentrues at a discount in a transaction taking place within the United States. 2. Interest accrued and paid on petitioner's american issue of debentures is not deductible from its income arising from such purchase. (Sec. 232, Revenue Act of 1934.)

1Opinion of the Court

CORPORATION DE VENTAS DE SALITRE Y YODA DE CHILE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Corporacion de Ventas de Salitre y Yoda v. Commissioner

Docket No. 97315.

United States Board of Tax Appeals

44 B.T.A. 393; 1941 BTA LEXIS 1334;

May 6, 1941, Promulgated

1. Petitioner, a foreign corporation, realized gain from the purchase of its own American debentrues at a discount in a transaction taking place within the United States.

2. Interest accrued and paid on petitioner's american issue of debentures is not deductible from its income arising from such purchase. (Sec. 232, Revenue…

2Cases cited10 opinions

  1. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  2. Helvering v. American Chicle Co.Supreme Court of the United States · 1934
  3. B. F. Avery & Sons, Inc. v. CommissionerUnited States Board of Tax Appeals · 1932
  4. Royal Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1938
  5. Carding Gill, Ltd. v. CommissionerUnited States Board of Tax Appeals · 1938

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