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CHOCK FULL O'NUTS CORPORATION v. UNITED STATES

No. 156, Docket 71-1536.

453 F.2d 300 (1971)

CHOCK FULL O'NUTS CORPORATION, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided December 21, 1971.

Attorney(s) appearing for the Case

Harry Geist, New York City, for plaintiff-appellant.

Michael I. Saltzman, Asst. U. S. Atty. (Whitney North Seymour, Jr., U. S. Atty., Michael D. Hess and Alan B. Morrison, Asst. U. S. Attys., New York City, on the brief), for defendant-appellee.

Stuart S. Opotowsky, Alan D. Berlin, New York City, for amicus curiae Hunt Foods & Industries, Inc.; Walter J. Rockler, Julius M. Greisman, Richard L. Hubbard, Washington, D. C., for amicus curiae J. P. Stevens & Co., Inc., Alex M. Gruder, Stamford, Conn., for amicus curiae Olin Corp.; Arnold & Porter, Washington, D. C., of counsel, on the brief for amici curiae.

Before MEDINA, MANSFIELD and MULLIGAN, Circuit Judges.

MANSFIELD, Circuit Judge:

This appeal raises the question, apparently one of first impression, whether a corporation which has issued callable convertible bonds at par is entitled under the Internal Revenue Code of 1954 and the Treasury Regulations promulgated thereunder by the Commissioner of Internal Revenue to deduct as "original issue discount" that part of the issue price allocable to the conversion feature.

The factual background is undisputed. Appellant...

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