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REYNOLDS METALS CO. v. COMMISSIONER

Docket No. 24939-93.

105 T.C. 304 (1995)

REYNOLDS METALS COMPANY & CONSOLIDATED SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 16, 1995.

Attorney(s) appearing for the Case

Robert A. Warwick and Frederick H. Robinson, for petitioners.

Lindsey D. Stellwagen and Kristine A. Roth, for respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' 1987 and 1988 Federal income taxes in the amounts of $430,030 and $357,028, respectively. The sole issue remaining in dispute is whether petitioners are entitled to a capital loss deduction for 1987, under section 165(f),1 with respect to certain convertible debentures issued by a wholly owned subsidiary and convertible into the stock of the...

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