International Tel. & Tel. Corp. etc. v. Commissioner
United States Tax Court
In our original opinion in this proceeding, we held that petitioners had not met their burden of proof as to the measure of any loss realized by ITT Avis or ITT Aetna on the retirement of convertible debentures. Petitioners' motion to reopen the record for submission of evidence on this issue was granted. Held, on the retirement of the debentures in 1965, ITT Avis and ITT Aetna sustained ordinary losses of $ 1,204,538 and $ 45,276.50, respectively.
1Opinion of the Court
SUPPLEMENTAL OPINION
Tannenwald, Chief Judge:
The original opinion in this proceeding, International Telephone & Telegraph v. Commissioner, 77 T.C. 60, was issued on July 9, 1981. In that opinion, we held that petitioners had not met their burden of proof as to whether any loss was realized by ITT Aetna Finance Co. (ITT Aetna) or ITT Avis, Inc. (ITT Avis), on the retirement of Avis, Inc. (Avis), and Aetna Finance Co. (Aetna) subordinate convertible debentures. See 77 T.C. at 72-84.
Petitioners timely filed a motion for leave to reopen the record for submission of additional evidence and for…
2Cases cited1 opinion
- International Tel. & Tel. Corp. etc. v. CommissionerUnited States Tax Court · 1981
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- International Telephone & Telegraph Corp. v. CommissionerCourt of Appeals for the Second Circuit · 1983
- International Tel. & Tel. Corp. etc. v. CommissionerUnited States Tax Court · 1981
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