SEABOARD FINANCE COMPANY v. COMMISSIONER

Docket No. 30554.

20 T.C. 405 (1953)

SEABOARD FINANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 21, 1953.


Attorney(s) appearing for the Case

Austin H. Peck, Jr., Esq., for the petitioner.

R. E. Maiden, Jr., Esq., for the respondent.


Respondent determined a deficiency of $70,590.74 in petitioner's income tax liability for the fiscal year ended September 30, 1947. Petitioner has conceded certain adjustments. The sole remaining question is whether petitioner's application of previously acquired Canadian currency, which had appreciated in value since its original acquisition, to consummate the purchase of the capital stock of a Canadian corporation resulted in an independently taxable gain, realized in Canada...

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