Legal Opinion
Capital One Financial Corp. v. Commissioner
Court of Appeals for the Fourth Circuit
Decided October 21, 2011No. 10-1788PublishedCited by 14 opinions
1Opinion of the Court
Affirmed by published opinion. Judge WILKINSON wrote the opinion, in which Judge NIEMEYER and Judge FLOYD joined.
OPINION
WILKINSON, Circuit Judge:
This case presents two questions, each born of the efforts of Capital One, a credit card issuer, to defer significant tax liability. The first question is whether Capital One can retroactively change the method of accounting used to report credit-card late fees on its 1998 and 1999 tax returns in such a fashion as would reduce its taxable income for those years by roughly $400,000,000. The second is whether Capital One can deduct the estimated costs…
2Cases cited32 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Brown v. HelveringSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Long Island Care at Home, Ltd. v. CokeSupreme Court of the United States · 2007
27 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- John Hancock Life Ins. Co. (U.S.A.) v. Comm'rUnited States Tax Court · 2013
- Peco Foods, Inc. & Subsidiaries v. Comm'rUnited States Tax Court · 2012
- Downs Racing, L.P. v. Com. of PACommonwealth Court of Pennsylvania · 2022
- Estate of Walsh v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 2026
- Giant Eagle Inc v. Commissioner IRSCourt of Appeals for the Third Circuit · 2016
9 more not listed; retrieve them via the Exa API.