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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