G.M. Trading Corp. v. Commissioner
United States Tax Court
Petitioner participated in a "Mexican debt-equity-swap" transaction. Held: 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. The value of the pesos received and the amount of gain determined.
1Opinion of the Court
G.M. Trading Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
G.M. Trading Corp. v. Commissioner
Docket No. 6983-91
United States Tax Court
103 T.C. 59; 1994 U.S. Tax Ct. LEXIS 45; 103 T.C. No. 4;
July 25, 1994, Filed
Decision will be entered under Rule 155.
Petitioner participated in a "Mexican debt-equity-swap" transaction. Held: 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. The value of the pesos received and the amount of gain determined.
R. James Curphy, for petitioner.
T.…
2Cases cited16 opinions
- Cottage Savings Assn. v. CommissionerSupreme Court of the United States · 1991
- United States v. Chicago, Burlington & Quincy RailroadSupreme Court of the United States · 1973
- Eder v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943
- National-Standard Co. v. CommissionerUnited States Tax Court · 1983
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
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