CMI International, Inc., a Michigan Corporation - Page 1

                                   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                            
                    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                 

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