G.M. Trading Corporation - Page 1

                                   106 T.C. No. 13                                    


                               UNITED STATES TAX COURT                                

                       G.M. TRADING CORPORATION, Petitioner v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent*                     


               Docket No. 6983-91.              Filed April 17, 1996.                 


                         On reconsideration, we decline to alter                      
                    any of the findings of fact or conclusions of                     
                    law set forth in our prior opinion at 103                         
                    T.C. 59 (1994).  Supplemental findings of                         
                    fact and conclusions of law made.                                 
                         Held, we adhere to our prior holding                         
                    that 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.  We also adhere to                        
                    our prior findings and conclusions regarding                      
                    the value of the pesos received and the                           
                    amount of gain realized.                                          





               This opinion supplements our prior opinion, G.M. Trading               
          Corp. v. Commissioner, 103 T.C. 59 (1994).                                  






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