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G.M. TRADING CORP. v. C.I.R.

No. 96-60679.

121 F.3d 977 (1997)

G.M. TRADING CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

September 12, 1997.

Attorney(s) appearing for the Case

R. James Curphy, Schoenbaum, Curphy & Scanlan, San Antonio, TX, Jerome B. Libin, Washington, DC, James Preston Fuller, Kenneth B. Clark, Jennifer Lynn Fuller, Rachel Hersey, Kelly Camille Mulholland, Fenwick & West, Palo Alto, CA, Noel Preston Brock, Sutherland, Asbill & Brennan, Washington, DC, for Petitioner-Appellant.

Steven W. Parks, Loretta Argrett, Asst. U.S. Atty. Gen., U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, Richard Bradshaw Farber, Department of Justice, Tax Division, Washington, DC, Charles Casazza, Clerk, U.S. Tax Court, Washington, DC, Stuart L. Brown, Chief Counsel, Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Before JOLLY, SMITH and DENNIS, Circuit Judges.

JERRY E. SMITH, Circuit Judge:

G.M. Trading Corporation ("G.M.") surrendered $600,000 worth of Mexican national debt to the Mexican government and received approximately 1.7 billion pesos restricted to the construction of a plant in Mexico. The Tax Court found that G.M. recognized $410,000 of gain. Concluding, to the contrary, that the pesos received in exchange for the debt extinguishment were worth $600,000, and the balance of the value received constituted a nontaxable...

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