Reynolds Metals Company and Consolidated Subsidiaries - Page 2

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               Robert A. Warwick and Frederick H. Robinson, for                        
          petitioners.                                                                 
               Lindsey D. Stellwagen and Kristine A. Roth, for respondent.             


                                       OPINION                                         

               TANNENWALD, Judge:  Respondent determined deficiencies in               
          petitioners' 1987 and 1988 Federal income taxes in the amounts of            
          $430,030 and $357,028, respectively. The sole issue remaining in             
          dispute is whether petitioners are entitled to a capital loss                
          deduction for 1987, under section 165(f),1 with respect to                   
          certain convertible debentures issued by a wholly owned                      
          subsidiary and convertible into the stock of the common parent               
          corporation.                                                                 
               All the facts have been stipulated.  The stipulation of                 
          facts and attached exhibits are incorporated herein by this                  
          reference.                                                                   
               Petitioners are the Reynolds Metals Company and Consolidated            
          Subsidiaries (the Reynolds Group).  The common parent is Reynolds            
          Metals Company (hereinafter referred to as Metals).  Metals is a             
          Delaware corporation with its principal place of business in                 
          Richmond, Virginia.  Metals and its consolidated subsidiaries                


          1 Unless otherwise indicated, all statutory references are to the            
          Internal Revenue Code in effect for the year in issue, and all               
          Rule references are to the Tax Court Rules of Practice and                   
          Procedure.                                                                   




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