Legal Opinion
National Can Corporation v. United States
Court of Appeals for the Seventh Circuit
Decided September 8, 1982No. 81-2461PublishedCited by 13 opinions
1Opinion of the Court
CUMMINGS, Chief Judge.
This case is about the tax treatment due a corporation that issues its own stock in order to satisfy the conversion option of its subsidiary’s convertible debentures. The parent corporation claims it should be allowed to amortize over the remaining life of the converted debentures the difference between the fair market value of the stock issued and the face value of the debentures, or else be allowed an immediate deduction for the same amount. The district court in a well-written opinion disallowed these deductions. 520 F.Supp. 567 (N.D.Ill.1981). We affirm.
I
The parties…
2Cases cited9 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Commissioner v. KorellSupreme Court of the United States · 1950
- Chock Full O' Nuts Corporation v. United StatesCourt of Appeals for the Second Circuit · 1971
- Shoong v. CommissionerSupreme Court of the United States · 1950
- Chicago, RI & P. Ry. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1931
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Pelfrey v. Educational Credit Management Corp.District Court, N.D. Alabama · 1999
- Honeywell, Inc. v. CommissionerUnited States Tax Court · 1986
- Southwestern Energy Co. v. CommissionerUnited States Tax Court · 1993
- Marathon Oil Company, Survivor by Merger of Husky Oil Company, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Tenth Circuit · 1987
- In Re BarryUnited States Bankruptcy Court, M.D. Tennessee · 1985
8 more not listed; retrieve them via the Exa API.