Intergraph Corporation and Subsidiaries - Page 2

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                  James R. McCann, David G. Glickman, Geoffrey R. Polma, and                              
            Sally C. Helppie, for petitioner.                                                             
                  Gary F. Walker, Kim Palmerino, and William T. Lundeen, for                              
            respondent.                                                                                   

                  SWIFT, Judge:  Respondent determined a deficiency of                                    
            $978,567 with respect to Intergraph Corp. (Intergraph) and its                                
            subsidiaries' consolidated 1987 Federal income taxes.                                         
                  After concessions, the issues for decision are:  (1) The                                
            deductibility of a claimed $1,923,103 foreign currency loss and                               
            of a claimed $520,432 interest expense; and (2) if the first                                  
            issue is decided against petitioner, the deductibility in the                                 
            year of payment of a $6,484,169 bad debt deduction claimed with                               
            respect to a payment Intergraph made of a Japanese-yen-                                       
            denominated debt obligation.                                                                  
                  Unless otherwise indicated, all section references are to                               
            the Internal Revenue Code in effect for 1987.                                                 

                                           FINDINGS OF FACT                                               
                  Some of the facts have been stipulated and are so found.                                
                  At the time the petition was filed, Intergraph was a                                    
            publicly held Delaware corporation with its principal place of                                
            business in Huntsville, Alabama.  During the relevant years,                                  
            Intergraph was the common parent of a group of affiliated                                     
            corporations engaged in the business of designing, manufacturing,                             
            and marketing computer graphics and data base management systems.                             




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