Hunt Foods and Industries, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent, 496 F.2d 532 (9th Cir. 1974)

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U.S. Court of Appeals for the Ninth Circuit - 496 F.2d 532 (9th Cir. 1974) May 20, 1974

On Appeal from a Decision of the Tax Court of the United States.

Walter J. Rockler (argued), Julius M. Greisman, Richard L. Hubbard, Arnold & Porter, Washington, D.C., Hilbert P. Zarky, Mitchell, Silberberg & Knupp, Los Angeles, Cal., Stuart S. Opotowsky, Alan D. Berlin, New York City, for petitioner.

Ernest J. Brown (argued), Scott P. Crampton, Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Lee H. Henkel, Jr., Acting Chief Counsel, IRS, Washington, D.C., for respondent.

Mac Asbill, Jr., Jerome B. Libin, David R. Woodward, Washington, D.C., for amicus curiae.

Before BROWNING and GOODWIN, Circuit Judges, and NIELSEN,¹ district judge.

OPINION

PER CURIAM:

The judgment of the Tax Court (see 57 T.C. 633) is affirmed. Chock Full O'Nuts Corp. v. United States, 453 F.2d 300 (2d Cir. 1971); AMF, Inc. v. United States, 476 F.2d 1351 (Ct. Cl. 1973). See generally, Fleisher & Cary, The Taxation of Convertible Bonds and Stocks, 74 Harv. L. Rev. 473 (1961).

Honorable Leland C. Nielsen, United States District Judge, Southern District of California, sitting by designation

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