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CENTEL COMMUNICATIONS CO. v. C.I.R.

No. 89-3650.

920 F.2d 1335 (1990)

CENTEL COMMUNICATIONS COMPANY, Successor in interest to Fisk Telephone Systems, Inc., Successor in interest to Fisk Telephone Systems, Inc. and Subsidiaries, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided December 17, 1990.

Attorney(s) appearing for the Case

Ethel R. Kaplan, McDermott, Will & Emery, Michael M. Conway, David B. Goroff, Frederic L. Hahn, Jay H. Zimbler, George R. Goodman, Hopkins & Sutter, Chicago, Ill., for petitioner-appellant.

Peter K. Scott, I.R.S., Richard Farber, Gary R. Allen, Steven Parks, Dept. of Justice, Tax Div., Appellate Section, Charles S. Casazza, U.S. Tax Court, Washington, D.C., for respondent-appellee.

Before CUMMINGS, CUDAHY and EASTERBROOK, Circuit Judges.

CUMMINGS, Circuit Judge.

The Tax Court held that Centel Communications Company ("Centel") was not entitled to deduct on its 1980 return the value of stock warrants issued to three of its stockholders in 1978 and exercised by them in 1980. At the same time, the Tax Court held that the three stockholders had no additional income when they exercised their warrants in 1980. We affirm.

I. BACKGROUND

Fisk Telephone Systems ("Fisk"), the predecessor of...

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