- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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