Legal Opinion

Capital One Fin. Corp. v. Comm'r

United States Tax Court

Decided May 22, 2008No. Nos. 19519-05, 24260-05Published

Ps' subsidiaries, Capital One Bank (COB) and Capital One, F.S.B. (FSB), issuers of Visa and MasterCard credit cards, earn income from late fees charged to cardholders who do not timely pay at least their minimum monthly payment due. From 1995 to 1997 COB and FSB included the late fees in income when the fees were charged to cardholders; i.e., when they accrued under the all events test. On Aug. 5, 1997, Congress enacted the Taxpayer Relief Act of 1997, Pub.

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Ps' subsidiaries, Capital One Bank (COB) and Capital One, F.S.B. (FSB), issuers of Visa and MasterCard credit cards, earn income from late fees charged to cardholders who do not timely pay at least their minimum monthly payment due. From 1995 to 1997 COB and FSB included the late fees in income when the fees were charged to cardholders; i.e., when they accrued under the all events test. On Aug. 5, 1997, Congress enacted the Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1004, 111 Stat. 911, which codified sec. 1272(a)(6)(C)(iii), I.R.C. This provision allows taxpayers who maintain a pool…

1Opinion of the Court

CAPITAL ONE FINANCIAL CORPORATION AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Capital One Fin. Corp. v. Comm'r

Nos. 19519-05, 24260-05

United States Tax Court

130 T.C. 147; 2008 U.S. Tax Ct. LEXIS 11; 130 T.C. No. 11;

May 22, 2008, Filed

Ps' subsidiaries, Capital One Bank (COB) and Capital One, F.S.B. (FSB), issuers of Visa and MasterCard credit cards, earn income from late fees charged to cardholders who do not timely pay at least their minimum monthly payment due. From 1995 to 1997 COB and FSB included the late fees in income when the fees were charged to…

2Cases cited36 opinions

  1. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  2. Casey v. CommissionerUnited States Tax Court · 1962
  3. Gitlitz v. CommissionerSupreme Court of the United States · 2001
  4. Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
  5. FPL Group, Inc. v. CommissionerUnited States Tax Court · 2000

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