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CLAYMONT INVESTMENT, INC. v. COMMISSIONER

Docket Nos. 14384-99, 9129-00.

90 T.C.M. 462 (2005)

T.C. Memo. 2005-254

Claymont Investments, Inc., as Successor in Interest to New Cci, Inc. and Subsidiaries v. Commissioner.

United States Tax Court.

October 31, 2005.

Attorney(s) appearing for the Case

William E. Bonano, Richard E. Nielsen, and Annie Huang (specially recognized), for petitioners.

James P. Thurston, Kevin G. Croke, and Usha Ravi, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

The issues for decision are whether: (1) Petitioners'1 claimed losses relating to customer relationships are deductible pursuant to section 165;2 (2) petitioners' arm's-length loan may, pursuant to section 482, be recast as a new loan to reflect the interest rate at the time of the subsequent assumption of the arm's-length loan; and (3) petitioners...

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