113 T.C. No. 1
UNITED STATES TAX COURT
CMI INTERNATIONAL, INC. A MICHIGAN CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24752-92. Filed July 13, 1999.
P's wholly owned domestic subsidiary, D,
participated in a debt-equity-swap transaction in which
D exchanged an interest in Mexican U.S.-dollar-
denominated debt for stock in D's Mexican subsidiary.
On its consolidated 1988 tax return, P reported no gain
or loss relating to the swap transaction. In the
notice of deficiency, respondent determined that P
recognized an $830,000 gain relating to the
transaction.
Held: Pursuant to sec. 367(a), I.R.C., and sec.
1.367(a)-1T(b)(3)(i), Temporary Income Tax Regs., 51
Fed. Reg. 17939, P did not recognize any gain.
James P. Fuller, Kenneth B. Clark, Jennifer L. Fuller,
William F. Colgin, James E. Beall, and Joseph A. Ahern, for
petitioner.
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