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NATIONAL ALFALFA DEHYDRATING & MILLING CO. v. COMMISSIONER

Docket No. 1081-70.

57 T.C. 46 (1971)

NATIONAL ALFALFA DEHYDRATING AND MILLING COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 14, 1971.

Attorney(s) appearing for the Case

Charles W. Hess and James J. Melching, for the petitioner.

David A. Pierce, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined a deficiency in petitioner's income tax for the fiscal year ended April 30, 1967, in the amount of $147,949.76.

The issue for decision is whether petitioner is entitled to a deduction for amortizable debt discount measured by the difference between the face value of its corporate bonds and the fair market value of its preferred stock which it received in exchange for the bonds.

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