TANDY CORP. v. UNITED STATES

No. 79-1289.

626 F.2d 1186 (1980)

TANDY CORPORATION, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

September 29, 1980.


Attorney(s) appearing for the Case

Allan Howeth, Whitfield J. Collins, William D. Ratliff, III, Fort Worth, Tex., for plaintiff-appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Ch., App. Sec. Tax Div., Dept. of Justice, Washington, D. C., Gary R. Allen, Tax Div., Donald B. Susswein, Dept. of Justice, Washington, D. C., for defendant-appellee.

Before TUTTLE, RANDALL and TATE, Circuit Judges.


RANDALL, Circuit Judge:

This case presents the question whether a corporation is entitled to deduct, for federal income tax purposes, the accrued interest and bond premium that would have been payable to holders of the corporation's convertible debentures called for redemption if such holders had not converted such debentures into common stock of the corporation prior to the redemption date. The district court held that the corporation was not entitled to deduct such...

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