Norwest Corporation and Subsidiaries - Page 53

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         principal face amount).  103 T.C. at 62, 65.  The taxpayer                   
         exchanged the $1.2 million debt for 1,736,694,000 pesos (Mex$),32            
         and the Mexican Government deposited the pesos in Procesos'                  
         restricted bank account.  The pesos were to be used to build a               
         lambskin processing plant.  Procesos issued shares of its stock to           
         the Mexican Government, which in turn transferred the shares to the          
         taxpayer. The U.S. company surrendered the debt to the Mexican               
         Government, which then canceled it.  Id. at 63-64.  The Court                
         rejected the taxpayer's view that the transaction was a tax-free             
         contribution to the capital of the Mexican subsidiary.  The Court            
         declined to disregard the taxpayer's exchange of U.S. dollar-                
         denominated debt for Mexican pesos and held that the taxpayer                
         realized a $410,000 gain on the exchange, equal to the difference            
         between the taxpayer's basis in the debt ($634,000) and the fair             
         market value of the pesos for which the debt was exchanged                   
         (Mex$1,736,694,000 with a fair market value of $1,044,000 on the             
         date of the transaction).  Id. at 68-71.                                     
              By analogy to G.M. Trading, respondent asserts that in the              
         instant situation we should decline to disregard petitioner's                


               32   The Mex$1,736,694,000 had a $1,044,000 fair market                
          value at the official exchange rate.  The $1.2 million debt had a           
          fair market value of $1,044,000 because of a 13-percent discount            
          rate of the debt's face value.  G.M. Trading Corp. v.                       
          Commissioner, 103 T.C. 59, 63 (1994), supplemented by 106 T.C.              
          257 (1996), on appeal (5th Cir., Oct. 4, 1996).                             






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