- 3 - under section 118, as a nontaxable capital contribution by the Mexican Government to petitioner or to Procesos. We have considered the arguments and voluminous material submitted by petitioner, by the amici curiae, and by respondent. We, however, remain convinced as to the correctness of our prior findings and opinion. Accordingly, we decline to alter any of the findings of fact or conclusions of law set forth in our prior opinion. Our prior opinion explained the general nature of the Mexican debt-equity-swap transaction that is at issue in this case, and we will not repeat that explanation. We, however, do make herein a number of supplemental findings of fact and conclusions of law, and we provide additional explanation for our opinion, as set forth below. For convenience, we combine our supplemental findings of fact and conclusions of law. All section 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. Value of Mexican Pesos It is argued by petitioner and by the amici curiae that the fair market value of the Mexican pesos that petitioner or Procesos, as petitioner's designee, received to construct and to operate a lambskin processing plant in Mexico should be presumed to be equal to or measured by petitioner's US$634,000 cost of participating in the transaction. We disagree. We continue toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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