Legal Opinion

Bank One Corporation v. Commissioner

United States Tax Court

Decided May 2, 2003No. 5759-95, 5956-97Unknown

1Opinion of the Court

120 T.C. No. 11

UNITED STATES TAX COURT BANK ONE CORPORATION (SUCCESSOR IN INTEREST TO FIRST CHICAGO NBD CORPORATION, FORMERLY NBD BANCORP, INC., SUCCESSOR IN INTEREST TO FIRST CHICAGO CORPORATION) AND AFFILIATED CORPORATIONS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 5759-95, 5956-97. Filed May 2, 2003. F, a financial institution, enters into bilateral contracts which are a type of derivative financial product known as interest rate swaps. Most of F’s swaps are of the plain vanilla type where one party (first party) agrees to pay to the other party (second party)…

2Cases cited98 opinions

  1. Daubert v. Merrell Dow Pharmaceuticals, Inc.Supreme Court of the United States · 1993
  2. Helvering v. TaylorSupreme Court of the United States · 1935
  3. Lucas v. American Code Co.Supreme Court of the United States · 1930
  4. Bob Jones University v. United StatesSupreme Court of the United States · 1983
  5. Caisse Nationale De Credit Agricole, a French Banking Corporation v. Cbi Industries, Incorporated, a Delaware Corporation, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1996

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