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.Page: 1 2 3 4 5 6 7 8 9 10 Next
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